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April 1st is Fast Approaching: Did You Update Your CRA Public File?
April brings many special events – baseball’s home opener, spring showers to bring May flowers, and let’s not forget the CRA Public File update. Section 43(e) of your bank’s CRA regulation states the Public File should be current as of April 1st each year. To help you, we’ve included some handy information to ensure your […]
FDIC Insurance – Communication is Key
Because of the recent Bank failures, your customers may feel skittish today. Although the news pundits all are saying deposit accounts are insured up to $250,000, we know this may not be the case. Consider having Management craft a statement message or online banking alert assuring customers their funds are insured. You should also ensure […]
Time to Put Your Junk in the Trunk?
The death knell for junk fees has sounded. There are emerging compliance risks surrounding junk fees that are gaining steam in Washington. While not new, the intensity or vigor of the current administrations’ pursuit of crimes (in their estimation) is increasing. Below is a link to two ABA article summaries which just came out on […]
FDIC Name Change – Updated
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 […]
TRID Fee Placement
Chart provides guidance on the placement of certain common fees on the loan estimate and closing disclosure.
Tolerance In 5 Years Monitoring
Tool to aid in validating TRID tolerances for the In 5 Years calculation on the loan estimate and total of payments calculation on the closing disclosure as well as Fee tolerance calculations. Use this tool to ensure your TRID calculations are accurate and fees paid by borrower(s) do not exceed TRID’s specific tolerance limitations.
HOEPA Calculation Worksheet for 2023 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 2022 – select the HOEPA Calculation Worksheet 2022.01.
