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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 […]
“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 3 of a 3 Part Series In our last article we recapped items necessary to comply with the Ability-to-Repay (ATR) and Qualified Mortgage (QM) requirements when underwriting the loan. Compliance with Regulation Z does not stop at origination. This article recaps the servicing requirements for ARM loans. Loan Servicing and The Bank’s Core System […]
Deployment of Servicemembers
Due to recent events overseas, there has been recent deployment of US troops with potential additional deployment to happen in the future. Interest rates are higher than they have been in the past; the current Prime Rate is at 8.5%. All financial institutions should be prepared for Servicemembers enacting their rights under the Servicemembers Civil […]
Corporate Transparency Act Implementation
FinCEN has published a flurry of Beneficial Ownership information in the last two weeks which has led many financial institutions to question how any of this information applies to them, and how their account opening processes will be affected by the new rule going into effect on January 1, 2024. The good news for financial […]
Regulatory Updates – Third Quarter 2023
Below is a link to the Regulatory Updates as of the end of Q3. 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 […]
In a Government Shutdown the National Flood Insurance Program Could be Affected
So, the Government may shut down. Again. This has happened before and will likely happen again. When this happens, one of the many “non-essential” services and programs is the National Flood Insurance Program (NFIP). So, what do we do if/when a shutdown happens? If there is a disruption to the NFIP, we should be prepared […]
New Threshold Amounts for 2024 under Regulation Z CARD Act, HOEPA and QM Sections
Based on the 4.6% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2023, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2024. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 4.9% increase […]
NCUA Updated Address for Adverse Actions
If you are not regulated by the NCUA then you can skip to the end of this Special Release. If you are regulated by the NCUA, then you need to know the CFPB amended some addresses in Regulation B, Regulation V and a website referencing Regulation Z APR Table. The August 25, 2023 Federal Register […]
“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 2 of a 3 Part Series In our last article, TCA recapped items necessary for origination and proper disclosure of ARM Loans. In this second article, we will review the requirements for complying with underwriting requirements unique to Adjustable-Rate Mortgages. Underwriting ARM Loans While banks are required to comply with the Ability-to-Repay standards in […]
