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Bank Secrecy Act: This Time, It’s Personal!
The headline reads more like the title of an action and adventure movie, but professionals who manage the day-to-day compliance with the Bank Secrecy Act know first-hand how much of an adventure their career path can take. As part of our annual BSA training, we often remind staff that the BSA carries both civil and […]
Important CTR Update – Compliance Date Moves From February 1, 2020 to September 1, 2020
TCA’s January 21, 2020 “CTR 101 Webinar” highlighted one key change to the FinCEN CTR report – the evolving expectations on how to complete Part I Item 2. The original October 1, 2019 Notice published required a February 1, 2020 compliance date. The January 17, 2020 Notice extends the compliance date for files to September […]
Loan Documentation Chart
We’ve been told that TCA’s Loan Documentation Chart is a popular tool that provides lenders a ready reference guide helping them ensure borrowers are given the right disclosures on a timely basis. Many of our clients have laminated the Chart and provided it to loan officers and processors to assist with loan documentation tasks. Keep […]
CRA Thresholds Announced for 2020
The annual CRA asset-size thresholds for covered financial institutions were announced on December 30, 2019 applicable for 2020. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. As a result of the 1.62% increase in the CPI, the […]
HMDA and HPML Thresholds Bumped Up for 2020
The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations and credit unions. Like the CRA thresholds, the adjustments are due to the annual percentage increase in the Consumer Price Index for Urban Wage […]
FinCEN Issues Guidance on Providing Financial Services to Hemp-Related Businesses
FinCEN and the regulators kicked off the holiday season by providing the industry with some clarification on the BSA implications of banking hemp-related businesses. In the News Release and Guidance, FinCEN said: “Because hemp is no longer a Schedule I controlled substance under the Controlled Substances Act, banks are not required to file a Suspicious […]
314(a) and 314(b) Information Sharing: Is there a Difference?
The goal of my article is to help BSA staff have a clearer understanding of the differences between mandatory and voluntary information sharing. TCA’s BSA Action Team (BAT) wants to point out some key observations based on our BSA audits. In BSA, information requests are commonly referred to as sections 314(a) and 314(b) of the […]
Regulation Z and Regulation M Dollar Thresholds for 2020
The Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds, which are tied to the Consumer Price Index, for Regulation Z and Regulation M exemptions. Loans or leases at or below the thresholds are subject to the protections of the regulations. The regulators have released the new […]
SAFE Act MLO Registration Renewal Period Starts November 1 Check Current Registrant’s Names
It’s that time again. The NMLS 2019 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 […]
Legislative and Regulatory BSA/AML Changes
Despite the collective efforts of law enforcement and BSA risk managers across the country, the United States is not doing the best job of finding effective and efficient ways to combat money laundering. Regulatory and legislative efforts, which are the truly meaningful actions that could be taken, are currently being worked on in Washington. A […]
