In Depth

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 […]

Joint intent exceptions are a common finding in our compliance reviews. We have found that there are misconceptions on what constitutes joint intent and how it should be documented; most of the questions come from commercial versus consumer mortgage loan officers. Many of the questions we are asked include: Isn’t the joint financial statement enough

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

The financing of manufactured homes is a niche market. Not all banks offer this type of financing because of the varying underwriting requirements, risk and limited salability of this type of loan. As a bank begins to investigate manufacturing home lending, it is often focused on prudent underwriting and the safety and soundness for this

A common acronym being discussed more and more in fair lending circles is REMA. The goal of this article is to establish a better understanding of what REMA is and how it can impact your bank. REMA is defined as the Reasonable Expected Market Area, which is the geographical area the regulatory agency believes a

These days, losses from Regulation E error claims are accepted by many institutions as the cost of doing business. Many institutions are relying more heavily upon internal and/or third-party fraud detection and prevention resources. But as you know, managing risk of loss is just part of the story. Regulation E compliance and financial risk continues

Part 1 of a 6-Part Series Network security, once thought of as an IT issue, is now Cybersecurity. A name change was necessary to keep up with the times, but no matter what it is called, is it still just an IT issue? We don’t think so. A shift in thinking and a different perspective

The government shutdown has ended for now, which is a relief to thousands of government workers. However, with another shutdown looming, many banks have asked in this period of uncertainty: How can we help affected individuals? Since we cannot predict the future, we thought the following would provide some ideas. The regulatory agencies have provided

Now that more than half the year is gone, many banks are starting to look more closely at their new 2018 HMDA LAR requirements because they have adequate volume to do testing. TCA wants to share with you what we have found in doing preliminary HMDA LAR validations. Many of the issues we’ve seen are

Exception reporting is not new; all banks are required to report loan policy and loan documentation exceptions for Safety and Soundness. However, a new unwritten rule is fair lending exception tracking covering pricing and underwriting exceptions on consumer loan products. Whether it’s HMDA for banks with less than or more than 500 entries, regulators want