David Mulkerin

Various regulatory agencies have released resources over the past couple weeks. As part of being a compliance partner and showing clients A Better Way with TCA, please see the following key insights. Appraisal FAQ Released On October 16, 2018, the OCC, FDIC and FRB released a joint Frequently Asked Questions document in response to comments […]

The NMLS Annual Renewal Period will begin November 1 and end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies will be able to complete their annual attestation that the company’s record is up to date, pay their NMLS processing

As we all well know, S.2155 provided some anticipated regulatory relief covering many areas. One of the relief items was HMDA relief, which TCA covered in a previous special release. As a quick refresher, the Act provides that an institution does not need to report data with respect to closed‐end mortgage loans if it originated

Based on the Consumer Price Index in effect on June 1, 2018, which increased 2.5%, the Consumer Financial Protection Bureau (CFPB) released a number of new threshold amounts which go into effect on January 1, 2019. They include:  The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged in

Hot on the heels of the release of the HMDA data tables for 2017, the CFPB/BCFP has released its tool for validity checking the correctness of your Institution’s HMDA file for the calendar year 2018 data being submitted in 2019. You can find this tool at https://ffiec.cfpb.gov/tools/file‐format‐verification. The tool does exactly what it says: verifies

The CFPB has released the public disclosures for HMDA data submitted for calendar year 2017. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As the tables are no longer required to be made a part of your CRA Public File, you can

On April 3, 2018, FinCEN issued a frequently asked questions (FAQ) document, FIN‐2018‐G001, discussing the Beneficial Ownership Rules which go into effect on May 11, 2018. The FAQ addresses the following topics, among others: Beneficial Ownership Threshold Interaction of the beneficial ownership threshold with other AML program obligations Collection of beneficial ownership information for direct

Thanks to an eagle‐eyed client for sharing with us a best‐kept secret that HUD released an updated SCRA Notice. As you know, the old form expired in December 2017. From what we can tell, the only changes to the notice are dates and the reference to 50 USC 3901‐4403, which was changed from the former

On March 13, 2018, the CFPB issued an updated Small Entity Compliance Guide (SEG) to incorporate recent 2018 changes to the Regulation E Prepaid Card rules which take effect on April 1, 2019. The Bureau released guidance for completing the short‐form disclosure for prepaid accounts, which includes not only a line‐by‐line how‐to but specifics on

On February 21, 2018, the FFIEC released a revised HMDA: Getting It Right guide (GIR) for Regulation C changes which took effect on January 1, 2018. The GIR is in the same format as previous guides and it includes the regulation, appendices and commentary in 12 CFR §1002 plus the CFPB tools. The GIR is