Special Release

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 top BSA hotline question TCA has received in August inquired about an update to FinCEN’s May 16, 2018 Exceptive Relief (FIN‐2018‐R002) delaying the requirement to obtain a Certification of Beneficial Ownership for certificate of deposit and loan renewals. Since FinCEN considered these to be new accounts, financial institutions expressed concerns over the many challenges

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

Last week the compliance and risk management worlds reacted with joy over the signing of Senate Bill S. 2155. For most bankers, the passing of this bill represented the most significant regulatory relief in decades. Of noted importance was the rollback of the expanded data collection rules for the Home Mortgage Disclosure Act (HMDA). However,

Many TCA clients have expressed concerns regarding FinCEN’s position that automatic renewals of certificates of deposits and loans are considered new accounts which require that a financial institution obtain a Certification of Beneficial Ownership for legal entity customers. Since FinCEN published the Frequently Asked Questions just one month prior to the mandatory compliance date, our

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

On April 10, 2018, the FFIEC issued a joint statement regarding Cyber Insurance and its role in Risk Management programs. With Cybersecurity events becoming commonplace, do you have the proper insurance to protect the bank and its assets? Although Cyber Insurance may be a part of the Risk Mitigation program, it is not the final

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