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Stay on the Right Side of Fair Lending: 2023’s Top 5 FAQs
Fair Lending remains a hot topic with regulators and special interest groups. During 2023, our clients experienced heightened scrutiny around identifying patterns of disparity that could result in discrimination allegations and enforcement actions. Review the five key issues clients have faced and consider evaluating them at your institution. TCA – A Better Way!
TCAs Client Top Five Deposit Missteps
Although there have been few new or changed regulations related to Deposit Compliance, missteps in compliance with these regulations can cause consumer harm. It’s important to stay focused and make sure staff changes or the implementation of new systems don’t increase errors at your institution. Helping institutions identify errors in deposit operations is a routine […]
FDIC Signage and Advertising – Things They Are A-Changin’
On December 20, 2023 the FDIC approved and issued a final rule regarding changes to 12 CFR 328: rules for the use of FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentations of Insured Status, and Misuse of the FDIC’s Name or Logo. The updated rules are effective April 1, 2024, with a mandatory compliance […]
CRA Asset-size Thresholds Announced for 2024
The annual CRA asset-size thresholds for covered financial institutions were announced by the FDIC and Federal Reserve on December 20, 2023 and by the OCC on December 26, 2023 applicable for 2024. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to […]
Regulatory Updates – Fourth Quarter 2023
Below is a link to the Regulatory Updates as of the end of Q4. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. TCA – A Better Way!
TCA’s Top Five Client Lending Compliance Findings
As we approach the end of 2023, we wanted to take some time to reflect and comment on some of the most common lending missteps we’ve seen while performing audits for Clients during the year. TCA’s Top Five are firmly rooted in two regulations that examiners spend much time and focus on. Regulation Z and […]
New CRA Provisions Effective as of April 1, 2024
2024 is right around the corner and there are a few provisions everyone needs to keep on their agenda to ensure compliance with the new CRA rules finalized on October 24, 2023. In an effort to help clarify the new rules, TCA reached out to the FDIC in Washington DC. The result of this call […]
HMDA and HPML Thresholds Bumped Up for 2024
On December 18, 2023, 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 pegged to the annual percentage increase in the Consumer Price […]
HOEPA Calculation Worksheet for 2024 Loans
Tool to calculate whether your loan transaction is subject to HOEPA based on the points and fees and prepayment penalties paid by the borrower. Worksheets are updated annually to reflect changes loan amount thresholds. Select the worksheet based on the year the loan has been originated. Example: loan originated in December 2023 – select the HOEPA Calculation Worksheet 2023.01.
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HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2024
On November 13, 2023, the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index (CPI-W) as of June 1. Loans or leases at or below the thresholds are subject to the protections […]
