Helping your team shape policies and procedures to strengthen your lending operations and allow you to withstand regulators' scrutiny
We perform exhaustive reviews to discover whether you're appropriately controlling and minimizing consumer lending risk.
Compliance in the consumer lending arena continues to get more complicated. Regulators have high expectations and there's an overflow of guidance from various federal agencies: CFPB, FDIC, OCC, and others. Plus, consumers have gotten savvier about their rights.
It's helpful to have a competent team to walk alongside you, ensuring that your lending policies are fair, that your loan servicing strategy is effective, and that you can measure, control, and minimize lending-related consumer risk and avoid consumer harm.
Numerous banks have placed their trust and confidence in TCA. Our team members, all former bankers, have real-life experience managing day-to-day consumer and mortgage lending compliance and preparing for regulatory exams.
We tap that deep expertise when we assess your loans, operations, and policies with the same scrutiny as examiners.
Our review includes:
- Looking at the consumer loan and mortgage documentation, checking for correct disclosures, borrowers' payments, and loan modifications.
- Ensuring that your written policies, procedures, products, and operations are current and reflect your agreement with borrowers.
- Identifying flood insurance coverage gaps.
- Evaluating your training and recommending changes, where necessary.
- Testing whether your procedures are adequate to minimize your risk.
Working with the TCA team is an investment in your future. Besides preparing for your exam, we advise you on modifications you can make to align your policies and procedures with your current needs and longer-term goals.
TCA's A Better Way for loan servicing and operations gives you the how-to on addressing your consumer lending risk.
Key deliverables include:
- Identifying compliance deficiencies and recommending corrections to help you pass future exams more easily
- Checking that you're complying with all relevant consumer and mortgage lending regulations
- Evaluating staff competence and training
Additional Compliance Topics
Fair Lending – The Latest
Regardless of bank size, complexity or risk profile, there is a universal myth when it comes to Fair Lending that there has been less enforcement since 2016. The truth is that Fair lending is one of the top enforcement rules. TCA recently attended a Fair Lending conference that included a regulatory panel discussion focusing on […]
Clarifying the Joint Intent Requirements at Application
Joint intent exceptions are a common finding in our compliance reviews. We have found that there are misconceptions on what constitutes joint intent and how it should be documented; most of the questions come from commercial versus consumer mortgage loan officers. Many of the questions we are asked include: Isn’t the joint financial statement enough […]
Fair Lending and Marketing in the Digital Age
There’s an old saying, “You don’t know what you don’t know” and that is certainly true when it comes to marketing initiatives meshing with the world of fair lending. The clash of both worlds and the often-divergent priorities have caused regulators to put this intersection under a microscope. A key fact today is that marketing […]
Financing Manufactured Homes Without Land
The financing of manufactured homes is a niche market. Not all banks offer this type of financing because of the varying underwriting requirements, risk and limited salability of this type of loan. As a bank begins to investigate manufacturing home lending, it is often focused on prudent underwriting and the safety and soundness for this […]
Understanding REMA
A common acronym being discussed more and more in fair lending circles is REMA. The goal of this article is to establish a better understanding of what REMA is and how it can impact your bank. REMA is defined as the Reasonable Expected Market Area, which is the geographical area the regulatory agency believes a […]
2019 Regulation E Claim Calendar
These days, losses from Regulation E error claims are accepted by many institutions as the cost of doing business. Many institutions are relying more heavily upon internal and/or third-party fraud detection and prevention resources. But as you know, managing risk of loss is just part of the story. Regulation E compliance and financial risk continues […]
