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
Mortgage Servicing Rules – Successor in Interest Part 3 of 3
Effective April 19, 2018, the Successors in Interest provisions will go into effect under RESPA. It is critical that institutions have procedures developed to address potential and verified Successors in Interest, as well as train appropriate staff as to the requirements under the Regulation. Part 3 of 3 focuses on this provision; refer to Part […]
Mortgage Servicing Rules Part 2 of 3
Most of the provisions of the final 2016 Mortgage Servicing Rules took effect on October 19, 2017, with the remaining provisions effective April 19, 2018. In Part 1 of this series, we focused on the Definition of Delinquency, Requests for Information, Force‐Placed Insurance, Prompt Payment and Crediting, and the Small Servicer Determination. Part 2 of […]
What is the Cloud Part 2: Risk Appetite Discussion
The goal of my last article was to eliminate the mystery of the “Cloud” by breaking it into easy‐to‐understand building blocks. A key takeaway is that the cloud is not a single operating option; it has many building blocks. The blocks or choices have a significant impact on your bank’s risk exposure. To make it […]
CRA Celebrated its 40th Year—Look for Greater Emphasis on Community Development Efforts
The Community Reinvestment Act (CRA) celebrated its 40th anniversary in 2017. The Act was established to ensure banks were meeting the credit needs of the community they designated as their assessment or market area, which often was a circle around their branches. Passing a CRA exam was less troublesome since bankers only had to be […]
HMDA Reporting for Loans Secured by Multiple Properties
We have received numerous questions about how to report multiple properties on the HMDA LAR for 2018. Quite frankly, it can be very confusing because some fields are reported on the property securing the loan and other fields are reported on the transaction. The commentary for §1003.4(a)(9) – 2 states the following: MULTIPLE PROPERTIES WITH […]
Making SAR Narratives Error‐Proof
Each SAR field is entered into FinCEN’s searchable database, so law enforcement can pull information or run inquires to aid investigations into financial and other illicit crimes. That’s why SARs are crucial. The law enforcement agencies are your audience and they need to know the whole “story” since they were not actively involved in the […]
