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1071 Preparation Guide | Article 5 What is an Application Date?
Application dates are sometimes a foreign concept in commercial lending. However, now that 1071 is a reality, commercial divisions everywhere will have asked themselves, “When do I have a completed application?” and perhaps the most important question of the day, “What will define my application date?” In commercial lending, it’s not as simple to determine […]
Back to School: Ready for Regulators’ Pop Quizzes?
With the summer winding down, the kids will be heading back to school and facing tests and the dreaded pop quizzes. But they are not the only ones. Compliance pros also must be ready for regulators’ tough questions. If your regulator were to give you a pop quiz, would you be ready? See if you […]
1071 Preparation Guide | Article 4 Identifying and Counting Covered Transactions
When implementing and creating processes for the 1071 Small Business LAR Rule, determining when the institution will be subject to the collection and reporting requirements is vital. The CFPB’s tiered implementation means we must first undertake a count to determine when the institution is subject to the collection and reporting of the covered data. The […]
1071 Preparation Guide | Article 3 Understanding the Flow of Commercial Lending
There is no doubt that the 1071 Small Business LAR Rule will change the way commercial lending departments operate. Compliance and Commercial Lending have not always gone hand in hand. Generally, there are lower compliance burdens for commercial purpose loans. As such, commercial lenders may be used to following strict guidelines and meeting regulatory requirements. […]
1071 Preparation Guide | Article 2 Identifying Stakeholders, Forming A Committee
Establishing a 1071 Implementation Committee is essential for your institution to ensure Regulation 1071 compliance. Your committee’s first order of business is preparing a risk assessment and reviewing the regulation to determine its impact on your processes and procedures. It also manages the project, prepares progress reports for stakeholders, addresses problems like delays and lack […]
1071 Preparation Guide – Article 1 Getting Started and Best Practices
We all knew more guidance on 1071 Dodd-Frank on Small Business Data Collection was coming. On May 17, 2024, the Consumer Financial Protection Bureau (CFPB) announced an interim final rule extending the compliance dates for data collection and data reporting for financial institutions. The Rule requires financial institutions to collect and report small business lending […]
1071 Preparation Guide Announcement
The Supreme Court has ruled on the constitutionality of the CFPB’s funding. I am somewhat surprised by the outcome and glad a decision was announced on May 16, 2024. A second Motion for Summary Judgement was filed by the TBA, Rio Bank, and the ABA, essentially saying that the Final Rule for 1071 “goes far […]
FDIC Issues Questions and Answers on New Signage Rule
On July 16, 2024, the FDIC published a Questions and Answers Related to the FDIC’s Part 328 Final Rule page on their website. The rule is effective as of April 1, 2024 with a mandatory compliance date of January 1, 2025. The FDIC expects to continually update the Q&A as needed. Like most Q&As, some […]
Regulatory Updates – Second Quarter 2024
Below is a link to the Regulatory Updates as of the end of Q2 2024. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. TCA – A Better Way!
AML Programs and Recent Consent Orders: What Questions Should you be Asking?
Last year’s news headlines screamed about financial crimes: the riveting cryptocurrency saga of Sam Bankman-Fried (SBF), Binance’s landmark $4.3 billion settlement with the Department of Treasury, and Deutsche Bank’s additional fines for anti-money laundering and sanctions failings. Other noteworthy stories entailed a parade of cybercrimes like ransomware and email scams. For those working in the […]
