Delivering the advice and expertise to measure, control, and manage lending-related consumer risk.
We ensure that your lending policies and procedures are satisfactory and keep you informed on staying on the right side of regulators.
No bank wants to emerge from an exam of its lending practices only to have regulators issue an MOU or something worse.
TCA makes sure that that doesn't happen to you.
Our team, all former bankers, has decades of experience conducting consumer compliance audits and helping banks adhere to the many alphabet lending regulations.
We know that the alphabet regs aren't perfectly designed: While complying with one, you may violate another. And we're also aware of how intense – and yes, often tedious – the audit process can get.
Still, it's an essential step to make sure you're serving and protecting your customers and not jeopardizing your bank.
We're here to ease the pressure on your team and serve as your third line of defense.
Our exhaustive scoping discussion gives us an in-depth understanding of your products and services, the policies and procedures you have in place, and your reasons for conducting business in a particular way.
Based on our findings, we develop an appropriate roadmap for our audit.
You can count on us to thoroughly review your policies to ensure they're adequate for the size and complexity of your bank and conduct transaction testing to verify your practices align with regulatory requirements and your stated policies and procedures.
Given that we do such audits daily, we quickly spot the discrepancies that give examiners pause and develop appropriate strategies for correcting and mitigating issues before an examiner finds and flags them.
Central to a sound CMS and receiving a satisfactory compliance exam are having an independent audit firm like ours catch problems, provide guidance on mitigating them, and retest before examiners arrive.
TCA provides A Better Way to reduce your lending-related consumer risk.
Key deliverables include:
- Bringing a seasoned perspective to auditing your lending practices
- Ensuring that your policies and procedures align with regulatory requirements
- Ensuring required disclosures and notices you provide to borrowers meet regulatory requirements
- Providing insight on hot topics and current pressure points from a regulatory point of view
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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