Helping you address the regulatory requirements associated with your Adjustable Rate Mortgages (ARMs)
We review your ARM documents and servicing practices, paying particular attention to routine errors that examiners focus on.
Given that interest rates have been low in recent years and fewer consumers likely have opted for ARMs, it would be normal if your staff’s proficiency in addressing all the compliance steps were a tad rusty.
Ours isn’t.
Reviewing ARM documents has always been a routine part of our business, and our team has remained up to date in all the regulatory requirements.
As such, we understand the latest changes and their impact on your operations.
Our team thoroughly reviews your portfolio of ARM loans to be sure that you comply with all the related regulations, including TRID, Reg X, and Reg Z.
We cover all the basics, like the timing, content, and terms of your rate adjustment notices and disclosures for every one of your ARM products.
We also dig deeper to identify the errors that bank examiners encounter most, whether they’re disclosure trip-ups, miscalculations, input mistakes, using an inappropriate or stale index, or incorrect principal loan balances.
We show you how to correct mistakes and implement a system to eliminate future errors.
Often, we also recommend and deliver training for mortgage servicing personnel.
Count on TCA’s A Better Way to ensure that your ARM compliance procedures are up to date and reflect the risks of your product line.
Key deliverables include:
- Assessing your compliance with Reg X and Reg Z
- Reviewing your method for providing rate change notices to ARM loan customers
- Recommending training or refreshers for mortgage servicing staff
- Ensuring your policies and practices address the risks associated with your suite of ARM products
Additional Compliance Topics
HMDA and HPML Thresholds Bumped Up for 2023
On December 28, 2022, 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 […]
New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections
Based on the 8.9% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2022, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2023. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 8.3% increase […]
Considerations for Managing an Offsite Review
They say change is constant and that’s never been truer than now. In our current reality of sheltering in place and social distancing, each day presents new challenges and opportunities. TCA’s article “COVID-19 Business Impact: What Can You Do to Help?” focuses on how institutions can help customers during the current pandemic, and on the […]
National Compliance Officer Day
Today is National Compliance Officer Day, so TCA® wanted to share some recommendations from our compliance team with our fellow compliance professionals on potentially banking clients who may be engaged in activities relating to the cannabis industry. The challenge of providing banking services for industrial hemp and CBD Oil is that there are no current […]
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