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“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 1 of a 3 Part Series For many years, we have experienced a low interest rate environment and originated predominantly fixed rate mortgages. Well times are changing – with the increase in interest rates, the popularity of Adjustable-Rate Mortgages is gaining momentum. We might be a little “rusty” in the process of originating and […]
1071 Small Business Loan Count Methodology
As we are all aware by now the Final Rule for the 1071 Small Business Data Collection was issued March 30, 2023. Many financial institutions are questioning where and how to start the process of identifying the small business loans to be counted. The final rule provides three methods to determine if a small business […]
A New Federal Holiday and an Old Federal Holiday – Alleviate The Confusion
So, if this article looks familiar, that’s because we sent out a similar version in the past two years and there is still some confusion as some institutions are open and some are closed. On June 17, 2021, the US got its first national holiday in 38 years. June 19 has been designated as “Juneteenth […]
FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion
The history of overdraft guidance goes back to 2005 with the Joint Guidance on Overdraft Protection Programs. The FDIC followed up with the Overdraft Payment Programs and Consumer Protection Final Overdraft Payment Supervisory Guidance in 2010 and the FDIC Overdraft Payment Program Supervisory Guidance FAQ in 2011. In 2019, the FDIC provided more information relating […]
FDIC Name Change – Updated, Again
On August 8, 2022 in the Federal Register (and a correction on August 12) the FDIC reported they had renamed the Consumer Response Center to the “National Center for Consumer and Depositor Assistance”. This Division is referenced in the Fair Housing regulation at 12 CFR 338 and in the Consumer Protection in Sales of Insurance […]
CFPB Bulletin – HMDA Address Issues
Most of you have likely received an email bulletin from the CFPB HMDA Help regarding data issues in reporting the Street Address Field. It’s important to note this is regarding errors in the Street Address field only and not in other fields such as City/State/Zip and has nothing to do with geocoding the Census Tract. […]
Regulatory Updates – First Quarter 2023
Below is a link to the Regulatory Updates as of the end of Q1. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. You can download the updates in a PDF form here. As always, TCA is here to help with A Better Way to answer all […]
The Anticipation is Over! Small Business LAR Final Rule Released
It’s here! The much anticipated and long awaited final Small Business LAR rule has been released! Rest assured TCA’s Small Business LAR Action Team (SBLAT) is on it. We’re working through the Final Rule to help you implement the new policies and procedures necessary to comply with the rule. Look for more articles from TCA […]
Small Business Data Collection – Are You Having the Conversation?
By Margaret Dolinger, CRCM 1071 Dodd Frank requires financial institutions to collect data on small business loans and record them on a Small Business Lending Application Register. The Consumer Financial Protection Bureau (CFPB) issued a Proposed Rule on October 8, 2021, regarding the covered institutions and covered transaction pursuant to proposed Regulation B 1002.101 – […]
Small Business LAR Action Team
Forward by Michelle Strickland All of us in the financial services industry have been patiently waiting for clarification of Section 1071 of the Dodd-Frank Act. The CFPB plans to have a final rule issued by March 2023 – and we are quickly running out of daylight to meet that date – One more week to […]