TCA published Part 1 on August 23, 2018 describing managing HMDA risk amid reporting uncertainty. Shortly thereafter, the CFPB published additional guidance on August 31, 2018, as noted the same day as our Special Release. Due to the HMDA ambiguity and uncertainty, TCA is committed to providing bankers with A Better Way to decipher various […]
HMDA Part 2: How to Report Purchased Loans Read More »
The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open‐end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do
HMDA Reporting Requirements: Business Purpose Loans Read More »
On April 26, 2018, the CFPB issued a final rule addressing utilization of a Closing Disclosure to reset tolerances under the TILA‐RESPA Integrated Disclosure Rule (TRID). Under the current regulation, a creditor may only use a Closing Disclosure to reset tolerances if there are fewer than four business days between the time the creditor is
New Rule for Using Closing Disclosure When Resetting Tolerances Read More »
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