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
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 […]
Regulatory Updates – Third Quarter 2022
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 […]
Do you Remember? HMDA – Reporting Open-End Lines of Credit
It’s time for a trip into the Way-Back Machine, all the way back to April 16, 2020, when the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C. This amendment permanently raised the closed-end coverage threshold from 25 to 100 closed-end mortgage loans in each of the two preceding calendar years. The […]
Renewed Focus on Overdraft and “Junk” fees
One of the consequences of shrinking interest rates and interest margins is that financial institutions’ reliance on non-interest income has significantly increased over the last decade. The Consumer Financial Protection Bureau (CFPB) published an initiative on January 26, 2022 stating its intention to research the impact of fees on American consumers. The press release specifically […]
B Prepared for Compliance in Commercial Lending
It’s common for many lenders to believe that commercial lending is exempt from federal compliance regulations. However, this would be untrue – commercial loans are subject to the following compliance regulations: Regulation C/HMDA, Flood Disaster Protection Act, and Regulation B/ECOA. This article will focus on only one the regulations above – Regulation B. Under this […]
2022 Census Tracts Changes What it May Mean for Your Assessment Area
The 2020 Census data has been released by the US Census – and it may impact your Assessment Area for CRA and your Lending Area for Fair Lending. The Federal Financial Institutions Examination Council (FFIEC) which provides uniformity and consistency in the supervision of financial institutions, incorporates the US Census data in a format that […]
