Special Release

Even though a topic may not fall under TCA’s typical umbrella of compliance, we often have broader compliance discussions with our clients that we feel are important to share for informational purposes; this is one of those instances. We were told by a banker that an examiner had cited a deficiency in the institution’s vendor

You may recall a 2017 article discussing the long-awaited Regulation CC changes which, after reading, we found out were not the changes compliance professionals were waiting for. Well, wait no longer! Like St. Louis Blues fans, the day you’ve been waiting for has arrived! OK, that’s a lot of excitement for Regulation CC, but it

TCA’s February 7, 2019 Special Release “Final Rules Released for Acceptance of Private Flood Insurance” said lenders can accept a private flood insurance policy and easily identify an acceptable policy. The rule suggests private providers add the following “compliance aid” clause: ‘‘This policy meets the definition of private flood insurance contained in 42 U.S.C. 4012a(b)(7)

On Monday, March 18, 2019, the FDIC joined the other prudential regulators in removing the requirement to make available the Annual Disclosure Statement required under 12 CFR 350, to simplify their regulation as the information is available through the FDIC’s website. The OCC and FRB had previously removed this requirement in 2017 and 1998, respectively.

Back in 2012, the Bigger-Waters Act required implementation of rules regarding standards for acceptance of flood insurance policies by non-NFIP insurers, commonly referred to as private flood insurance. In October 2013, the regulators published a proposed rule. On January 28, 2019, the FDIC was the first regulator to release the joint rulemaking but we expect

The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset‐size exemption thresholds for banks, savings associations and credit unions. Like the CRA thresholds, the adjustments are due to the annual percentage increase in the Consumer Price Index for Urban Wage

On December 21, 2018, the President signed legislation that extended the National Flood Insurance Program’s (NFIP’s) authorization to May 31, 2019. All was well for another six months, or so everyone (including Congress) thought. On December 27th, FEMA ruled that the NFIP extension doesn’t allow for its continuation during the ongoing government shutdown. This decision

On November 20, 2018, FEMA posted a press release reminding interested parties that the National Flood Insurance program (NFIP) expires at 11:59 p.m. on November 30, 2018. While FEMA is confident Washington will vote to reauthorize the NFIP, if a lapse were to occur, it would not impact policies already in effect. We will continue