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Small Business Data Collection – Are You Having the Conversation?
By Margaret Dolinger, CRCM 1071 Dodd Frank requires financial institutions to collect data on small business loans and record them on a Small Business Lending Application Register. The Consumer Financial Protection Bureau (CFPB) issued a Proposed Rule on October 8, 2021, regarding the covered institutions and covered transaction pursuant to proposed Regulation B 1002.101 – […]
Small Business LAR Action Team
Forward by Michelle Strickland All of us in the financial services industry have been patiently waiting for clarification of Section 1071 of the Dodd-Frank Act. The CFPB plans to have a final rule issued by March 2023 – and we are quickly running out of daylight to meet that date – One more week to […]
April 1st is Fast Approaching: Did You Update Your CRA Public File?
April brings many special events – baseball’s home opener, spring showers to bring May flowers, and let’s not forget the CRA Public File update. Section 43(e) of your bank’s CRA regulation states the Public File should be current as of April 1st each year. To help you, we’ve included some handy information to ensure your […]
FDIC Insurance – Communication is Key
Because of the recent Bank failures, your customers may feel skittish today. Although the news pundits all are saying deposit accounts are insured up to $250,000, we know this may not be the case. Consider having Management craft a statement message or online banking alert assuring customers their funds are insured. You should also ensure […]
Time to Put Your Junk in the Trunk?
The death knell for junk fees has sounded. There are emerging compliance risks surrounding junk fees that are gaining steam in Washington. While not new, the intensity or vigor of the current administrations’ pursuit of crimes (in their estimation) is increasing. Below is a link to two ABA article summaries which just came out on […]
FDIC Name Change – Updated
On August 8, 2022 in the Federal Register (and a correction on August 12) the FDIC reported they had renamed the Consumer Response Center to the “National Center for Consumer and Depositor Assistance”. This Division is referenced in the Fair Housing regulation at 12 CFR 338 and in the Consumer Protection in Sales of Insurance […]
TRID Fee Placement
Chart provides guidance on the placement of certain common fees on the loan estimate and closing disclosure.
Tolerance In 5 Years Monitoring
Tool to aid in validating TRID tolerances for the In 5 Years calculation on the loan estimate and total of payments calculation on the closing disclosure as well as Fee tolerance calculations. Use this tool to ensure your TRID calculations are accurate and fees paid by borrower(s) do not exceed TRID’s specific tolerance limitations.
