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New Threshold Amounts for 2022 under Regulation Z CARD Act, HOEPA and QM Sections
Based on the 4.7% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2021, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2022. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged. (1026.6(b)(2)(iii) […]
Safe Act MLO Registration Renewal Period Starts November 1 – Check Current Registrants’ Names
It’s that time again. The NMLS 2021 Annual Renewal Period began on November 1 and will end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies can complete their annual attestation that their record is up to date, pay their […]
OCC Updated Addresses for Equal Housing, CRA and Adverse Actions
If you are not regulated by the OCC, then you can skip to the end of this Special Release. If you are regulated by the OCC, then you need to know the OCC issued Bulletin 2021-35 on August 5, 2021 updating addresses used for the Equal Housing Lender lobby posters, CRA lobby notices for the […]
CFPB Releases HMDA Public Data Tables
The CFPB has released the public disclosures for HMDA data submitted for calendar year 2020. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As a reminder, the tables are no longer required to be made a part of your CRA Public File. […]
Covid-19 and Compliance Engagements – Update
Throughout this pandemic, TCA Compliance has looked to the Centers for Disease Control and Prevention (CDC) for guidance on how best to manage the effects of COVID-19 on our business. As many states, including Illinois, are entering into Phase 5 of their COVID strategies (i.e. are re-opening), we have continued to look to the CDC […]
A New Federal Holiday. What Now?
On June 17, 2021, the U.S. got its first new National Holiday in 38 years. June 19th has been designated as “Juneteenth National Independence Day.” Our last new National Holiday, Martin Luther King, Jr. Day, the third Monday in January, was instituted in 1983. So, what’s different about these holidays and why does it affect […]
OCC’s CRA June 2020 Final Rule – Maybe
For those of you regulated by the OCC and trying to plan the implementation of the June 2020 final CRA rule – Look Out! In OCC Bulletin 2021-24, issued May 18, 2021, the OCC stated that it will “Reconsider” the CRA Final Rule. Yes, you read that correctly. As many financial institutions and software vendors […]
When the Tide is Against You
Over the past several months, the banking industry has experienced tremendous loan origination volume. While increased loan production is a good thing, it is important for Compliance Managers to stay cognizant of rising risks. Pressure, whether from peers or self-imposed, to push loans through leads to a breakdown in controls that are caused from procedural […]
HMDA – Field Reporting Exemption under EGRRCPA – When does a Bank Lose this Exemption?
Under the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRPA), many banks were exempt from reporting all fields on the HMDA LAR as they had originated fewer than 500 closed-end HMDA Reportable loans or fewer than 500 open-end HMDA Reportable loans during the prior calendar year. With the dramatic upturn in production during the […]
The Great Debate — Is This a Finance Charge?
If only there was a simple answer! Unfortunately, this seemingly simple question can be endlessly debated due to the complexity of Regulation Z. §1026.4(a) states that a finance charge is the cost of consumer credit as a dollar amount. It includes any charge payable directly or indirectly by the consumer and imposed directly or indirectly […]
