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Covid-19 and Compliance Engagements
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. Now that stay-at-home orders are being lifted and businesses are reopening, we’ve again relied on the CDC in developing a strategy to protect the health […]
FinCEN Guidance on Medical Scams and COVID-19
As we continue to adjust with the evolving pandemic, FinCEN published two documents to keep awareness high. The May 18, 2020 Notice provides a current update to meet the various BSA reporting, recordkeeping and monitoring requirements. Here are a few of the key points: BSA Reporting Requirements – As noted in TCA’s earlier article BSA […]
Loan Servicing & Loss Mitigation Are Fair Lending Risks Too!
As we are all in this unusual time of a pandemic with various levels of lockdowns and social restrictions and the resulting economic downturn, unemployment and business closures, many financial institutions are trying to wade through processes on how to help their customer base through modifications, deferments, waiving of fees and loan proceeds for small […]
Do These Activities Qualify for CRA Credits?
COVID-19 has caused nationwide turmoil, including in the financial services industry. Banks have been flooded with inquiries regarding deferral of payments, modification of loan provisions and loan requests to keep businesses afloat. Many banks have asked TCA whether certain activities would be considered as CRA credits or qualified community development activities. The first of many […]
Preparing a Bank Secrecy Act Risk Assessment
Welcome to TCA’s BSA Back to Basics article series! Each month, our BSA experts will explore a section of the FFIEC BSA/AML Exam Manual, analyze the regulatory requirements, and offer insights to common findings in exams and audits. We will share best practices to help your BSA program continue to evolve. The first section of […]
UPDATE: Unlimited Savings Withdrawals Are a Reality
Ever since I’ve been in banking, Congress was going to relax the six-transaction limitation from savings and money market accounts. We won’t talk about how long that’s been, but it’s been a while. All it took was a global pandemic. Bankers and consumers have gotten their wish. (Actually, the FRB has been looking at this […]
Big Increase to Foreign Remittance Transfer Threshold
The CFPB released a Regulation E Update regarding remittance transfers and increasing the safe harbor threshold from 100 to 500 transactions per calendar year, effective July 21, 2020. Regulation E requires remittance transfer providers to provide customers with certain disclosures and establishes cancellation and error resolution procedures for these foreign transactions. Also, the update memorialized […]
Privacy Notice Opt-Out Requirements
TCA has received questions from several clients recently regarding privacy notices and opt-out requirements, so we felt it was time to provide a refresher. Questions on whether written agreements meet the requirements for joint marketing arrangements should be referred to legal counsel. What information is covered? The GLB Privacy Rule protects a consumer’s “nonpublic personal […]
CFPB Waives TRID and Rescission Timeframes
On April 29, 2020, the Consumer Financial Protection Bureau released an interpretive ruling effective on May 4, 2020 providing rescission relief. If a consumer refinances or applies for a mortgage loan and needs funds due to the COVID-19 pandemic before the end of the waiting periods, lenders can waive and modify the waiting period for […]
