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HMDA Open-End Credit Threshold Maintained through 2021
On October 10, 2019, the CFPB released a final rule (not yet published in the Federal Register) extending the current 500 open-end credit threshold until January 1, 2022. This new rule is effective on January 1, 2020. In addition to the rule above, the Bureau has issued an Executive Summary and an “unofficial, informal” redline […]
Appraisal Threshold Increased to $400,000
Get ready to update those policies and procedures! On September 27, 2019, the OCC, FDIC and FRB, in concurrence with the CFPB, published a revision to the appraisal rules at 12 CFR 34, 225 and 323 increasing the threshold amount where a residential real estate transaction requires a state-licensed, certified appraiser from $250,000 to $400,000. […]
Ready for HDMA 2020?
Well, the CFPB is well on the way! On September 25, 2019, they released the 2020 HMDA Filing Instructions Guide (FIG) for data collected in 2020 and reported in 2021. Besides timing and changing references of “2019” to “2020,” the changes appear to be items like updated descriptions and instructions for certain fields and revisions […]
Cannabis Bill Passes U.S. House
On the eve of National Compliance Officer Day (and ironically when TCA published a discussion on banking industrial hemp), the United States House of Representatives passes H.R.1595 Safe Banking Act of 2019 which, if signed into law, would protect financial institutions from examiner criticism for providing banking services to cannabis-related businesses. The bill provides for […]
National Compliance Officer Day
Today is National Compliance Officer Day, so TCA® wanted to share some recommendations from our compliance team with our fellow compliance professionals on potentially banking clients who may be engaged in activities relating to the cannabis industry. The challenge of providing banking services for industrial hemp and CBD Oil is that there are no current […]
Fair Lending – The Latest
Regardless of bank size, complexity or risk profile, there is a universal myth when it comes to Fair Lending that there has been less enforcement since 2016. The truth is that Fair lending is one of the top enforcement rules. TCA recently attended a Fair Lending conference that included a regulatory panel discussion focusing on […]
CFPB Releases HMDA Public Data Tables
The CFPB has released the public disclosures for HMDA data submitted for calendar year 2018. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As the tables are no longer required to be made a part of your CRA Public File, you can […]
New Threshold Amounts for 2020 under Regulation Z CARD Act, HOEPA and QM Sections
Based on the 1.9% increase in the Consumer Price Index in effect on June 1, 2019, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2020. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged. (1026.6(b)(2)(iii) and […]
Examiners Stress Independent Audit Critical to BSA Success
On July 22, 2019, the prudential regulators issued FIL-43-2019 making a joint statement on BSA/AML risk-based approaches in examinations. TCA’s BAT reviewed the statement and took away three key points: transparency, risk assessment and independent audit. Transparency – The statement states: “This statement is intended to improve transparency into the risk-focused approach used for planning […]
New MSA Codes, 2019 Demographic Changes and 2018 HMDA Aggregate Data
We’ve received a lot of inquiries on what happened with the 2019 MSA codes: When will the pending 2019 demographic information changes be released? Has the 2018 HMDA Aggregate Data been announced? This “Special Delivery” will provide the most current information available to these questions. New MSA Codes Confusion In April 2018, OMB Bulletin No. […]
