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SAFE Act MLO Registration Renewal Period Starts November 1
It’s that time again. The NMLS 2020 Annual Renewal Period will begin November 1 and 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 NMLS […]
Three Hot CRA Concerns
Minding the pandemic, election and social issues is a lot to focus on but bankers will have to add the Community Reinvestment Act (CRA) to their full plates. There are three hot CRA topics on which to focus since CRA is still very much on the regulatory agencies’ minds. Despite 2020 upending CRA lending programs, […]
SCRA Notice Changes
We are not sure when it occurred, but HUD slipped in two changes to the SCRA notice since it was last changed in March 2018. Both changes are in the final section within two bullet points. In the first bullet point, the website address for the Military Legal Assistance Office Locator was shortened, presumably to […]
TCA IS ON THE MOVE!
TCA has moved our corporate headquarters from Chicago to Oak Brook, Illinois. While we are sad to leave our home for the past 30 years, we are excited for the new opportunities our new headquarters will provide. Given its central location, our new office is easily accessible from downtown Chicago, the suburbs, the airports, and […]
Ready for HMDA 2021 Filing?
On August 21, 2020, the CFPB released the 2021 HMDA Filing Instructions Guide (FIG) for data collected in 2020 and reported in 2021. Besides changing the references of “2020” to “2021,” the other changes are less cosmetic, such as updated descriptions and instructions for certain fields and revisions to certain edits. Also, we note they […]
Lots of Regulation Z Updates
Based on the 0.1% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2020, the Consumer Financial Protection Bureau (CFPB) released a number of new triggering thresholds which go into effect on January 1, 2021. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged. […]
New Hemp-related Business Guidance
On June 29, 2020, FinCEN published FIN-2020-G001 providing guidance for obtaining due diligence information for hemp-related businesses. The BSA industry has wrestled with cannabis and its derivative rules since FinCEN’s initial 2014 guidance for banking marijuana-related businesses. Between 2014 and 2018, hemp was equated with marijuana since both are derived from the same plant. However, […]
Adverse Action Notice Requirements For Loans and Deposits
When you deny a credit application or a deposit account request, you simply fill out a form and move on to the next customer, right? If only it were that simple! This article will clarify the who, what and why of the different requirements for denying loan applications and deposit requests for consumers and businesses […]
LIBOR – CFPB Proposes Amendments to Reg Z to Facilitate Transition
We have all heard that the LIBOR index may no longer be available after 2021 and over the past year TCA has received many questions regarding the transition from the LIBOR. How do we prepare? What is the replacement index? Is there advance notice required? On June 2, 2020, the CFPB released three items related […]
Limited Open-End Credit eSign Exemption Due to COVID-19
The Consumer Financial Protection bureau released a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic. This is described as a temporary and targeted flexibility for credit card issuers during this pandemic regarding the electronic provision of certain disclosures required to be in writing. Regulation Z generally […]