On April 16, 2020, The Consumer Financial Protection Bureau issued a final rule raising the loan-volume coverage thresholds in Regulation C for financial institutions reporting data under the Home Mortgage Reporting Act (HMDA). A permanent threshold for collecting closed end mortgage reporting data went from 25 to 100 loans effective July 1, 2020. Also, open-end […]
No Longer A HMDA Reporter – Fair Lending Still Applies Read More »
If your institution is regulated by the FDIC or FRB, you can stop reading here, unless you want to see what could be coming your way in the near future. The OCC published a final Community Reinvestment Act rule on June 5, 2020 which marks a departure from the OCC, FDIC and FRB being “in
OCC Banks: Have You Hung Up Your New CRA Lobby Notice Yet? Read More »
Minding the pandemic, election and social issues is a lot to focus on but bankers will have to add the Community Reinvestment Act (CRA) to their full plates. There are three hot CRA topics on which to focus since CRA is still very much on the regulatory agencies’ minds. Despite 2020 upending CRA lending programs,
Three Hot CRA Concerns Read More »
As we are all in this unusual time of a pandemic with various levels of lockdowns and social restrictions and the resulting economic downturn, unemployment and business closures, many financial institutions are trying to wade through processes on how to help their customer base through modifications, deferments, waiving of fees and loan proceeds for small
Loan Servicing & Loss Mitigation Are Fair Lending Risks Too! Read More »
COVID-19 has caused nationwide turmoil, including in the financial services industry. Banks have been flooded with inquiries regarding deferral of payments, modification of loan provisions and loan requests to keep businesses afloat. Many banks have asked TCA whether certain activities would be considered as CRA credits or qualified community development activities. The first of many
Do These Activities Qualify for CRA Credits? Read More »
Regardless of bank size, complexity or risk profile, there is a universal myth when it comes to Fair Lending that there has been less enforcement since 2016. The truth is that Fair lending is one of the top enforcement rules. TCA recently attended a Fair Lending conference that included a regulatory panel discussion focusing on
Fair Lending – The Latest Read More »
We’ve received a lot of inquiries on what happened with the 2019 MSA codes: When will the pending 2019 demographic information changes be released? Has the 2018 HMDA Aggregate Data been announced? This “Special Delivery” will provide the most current information available to these questions. New MSA Codes Confusion In April 2018, OMB Bulletin No.
New MSA Codes, 2019 Demographic Changes and 2018 HMDA Aggregate Data Read More »
There’s an old saying, “You don’t know what you don’t know” and that is certainly true when it comes to marketing initiatives meshing with the world of fair lending. The clash of both worlds and the often-divergent priorities have caused regulators to put this intersection under a microscope. A key fact today is that marketing
Fair Lending and Marketing in the Digital Age Read More »
Several staff members of Thomas Compliance Associates (TCA) attended the recent CRA & Fair Lending Colloquium and obtained valuable information from the sessions. One theme that stood out and presenters stressed was that bankers can help shape the re-write of the Community Reinvestment Act (CRA) regulation. The Office of the Comptroller of the Currency (OCC)
Submit Comments to CRA Modernization Initiative Read More »
Much has happened since the beginning of 2018, especially in the world of HMDA. This is Part 3 in TCA’s series of HMDA articles. Part 1 focused on managing HMDA risk amid reporting uncertainty and Part 2 focused on HMDA reporting for purchased loans. One HMDA data collection change that has surfaced is causing headaches
HMDA Part 3: Dropped MSA Codes Impact Fair Lending Review Read More »
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