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Regulation Z and Regulation M Dollar Thresholds for 2019
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 regulatory protections. The regulators have released the new index limit for […]
Here We “GTO” Again Real Estate Geographic Target Orders Expande
On November 15, 2018, FinCEN announced the expansion of the existing real estate geographic target orders (GTO) to include 12 more metropolitan areas. As covered in previous TCA Special Delivery articles, a series of GTOs measures became effective March 1, 2016 which temporarily required certain U.S. title insurance companies in the Borough of Manhattan, New […]
Submit Comments to CRA Modernization Initiative
Several staff members of Thomas Compliance Associates (TCA) attended the recent CRA & Fair Lending Colloquium and obtained valuable information from the sessions. One theme that stood out and presenters stressed was that bankers can help shape the re-write of the Community Reinvestment Act (CRA) regulation. The Office of the Comptroller of the Currency (OCC) […]
What do CDD and EDD Mean? Part I: Customer Due Diligence
What is all the buzz about customer due diligence (CDD) and enhanced due diligence (EDD)? The expectations for CDD and EDD did not change with the addition of the 5th BSA pillar. The expected due diligence requirements were simply codified. TCA® first addressed this topic in depth in a 2015 article. What does that mean […]
FFIEC Releases 2017 CRA Public Data Tables
On October 25, 2018, the FFIEC released the public disclosures for CRA data submitted for the calendar year 2017. Institutions that report CRA data should go to the FFIEC website and download their disclosure tables for availability on request. The report should be made a part of your CRA Public File within three business days […]
Regulatory Announcements October 2018
Various regulatory agencies have released resources over the past couple weeks. As part of being a compliance partner and showing clients A Better Way with TCA, please see the following key insights. Appraisal FAQ Released On October 16, 2018, the OCC, FDIC and FRB released a joint Frequently Asked Questions document in response to comments […]
TRID is all grown up – now what? TRID Exams Get Tougher
Happy Birthday, TRID! It’s hard to believe but the TILA/RESPA Integrated Disclosure Rule is three years old this October! Remember when it was a cute little Reg? No? I must confess, neither do I! From the onset of compliance in October 2015 to the publication of the final rule on July 7, 2017, TRID remains […]
SAFE Act MLO Registration Renewal Period Starts November 1 Finding Your MLO’s Registration Can be Tricky
The NMLS 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 will be able to complete their annual attestation that the company’s record is up to date, pay their NMLS processing […]
ACH Activity: Are You Managing Your BSA Risk?
The Bank Secrecy Act requires banks to manage risks associated with automated clearinghouse (ACH) and international ACH transactions (IAT), which results in a need for effective risk mitigation strategies and monitoring processes. The sheer volume of ACH activity makes the task seem impossible. TCA’s BSA Action Team (BAT) can help evaluate the effectiveness of a […]
The New Compliance Audit Expectation
Bankers have had whiplash over the last five years with new regulations, delayed regulations, regulatory relief and changes to new rules within one year from the initial effective date. Now on top of all of the changes, there are two more significant developments. First, compliance examinations have changed and consumer harm is the new hot […]