Specialties
Deposit Regulations
Overdraft Protection Program Review
Delivering Support that Mitigates Risk, Services Customers, and Protects Your Reputation
We provide knowledge, experience, and guidance that allow your bank to adhere to consumer protection laws and manage their complexities.
Consumer compliance professionals face a daunting task trying to stay up on the changing consumer compliance landscape and fully understanding the implications that every regulatory change has on your bank.
That's where we come in.
We've spent decades building our expertise in this complex and often conflicting area of compliance. That experience has given us a ringside seat on how banks find themselves in regulatory trouble.
Whatever your challenge, we've likely seen something similar, and we have the expertise to review all applicable federal consumer regulations, from Regulation B to Regulation Z.
Still, we know that each bank is unique.
That’s why we start each engagement by gaining a 360-degree view of your bank operations and culture before conducting any audits, reviews, and testing.
This initial process allows us to understand your unique risk, pinpoint areas of concern, and recommend an appropriate review scope. Our approach helps you mitigate your risk and prepare for your next regulatory exam.
We also enhance your compliance culture by providing sensible recommendations and best practices throughout the process to help you put corrective action in place.
After all, protecting and serving your customers are crucial to building your community's trust, maintaining your reputation, and strengthening your bank.
TCA provides A Better Way to manage your consumer compliance obligations.
Key Deliverables Include:
- Lending, Loan Origination, and Loan Servicing – Review practices, policies, and procedures to measure, control, and minimize lending-related consumer risk.
- Deposit-related regulations and statutes – Review practices, policies, and procedures to measure, control, and minimize deposit-related consumer risk.
- Home Mortgage Disclosure Act (HMDA) – Ensure the data reported on your loan application register (LAR) is accurate prior to the required filing date.
- Compliance Management System (CMS) – Ensure that your CMS reflects your current risk and meets regulatory expectations for board and management oversight, effective monitoring and audit schedules, and policies and procedures to mitigate consumer harm.
Consumer Compliance Insights
Identifying Higher Risk Customers using Keyword Searches
Financial institutions are facing increased regulatory pressure on Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures, particularly regarding inherently higher-risk customer types. CDD is critical to identifying and monitoring customers involved in higher-risk activities. Identification of higher-risk customers starts at account opening and your account opening procedures should incorporate this due diligence. Some […]
Regulatory Updates – First Quarter 2022
Below is a link to the Regulatory Updates as of the end of Q1. 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 […]
CFPB’s UDAAP Is Seriously Looking for Illegal Discrimination Practices
The Consumer Financial Protection Bureau (CFPB) announced on March 16, 2022, the added scrutiny of illegal discriminatory practices within its examination procedures for Unfair, Deceptive, Abusive Acts and Practices (UDAAP). The CFPB considers that illegal discrimination practices based on services or products can cause consumer harm; therefore, UDAAP should be included with the other Fair […]
Regulatory Updates – 2021
It’s challenging for every Compliance professional to stay on top of the small and big changes to existing and new regulatory requirements. As you partner in compliance, we are introducing a new feature to our Regulatory Compliance Manager (RCM) Service – Quarterly Regulatory Updates. This is A Better Way for you to keep track of […]
When the Tide is Against You
Over the past several months, the banking industry has experienced tremendous loan origination volume. While increased loan production is a good thing, it is important for Compliance Managers to stay cognizant of rising risks. Pressure, whether from peers or self-imposed, to push loans through leads to a breakdown in controls that are caused from procedural […]
The Great Debate — Is This a Finance Charge?
If only there was a simple answer! Unfortunately, this seemingly simple question can be endlessly debated due to the complexity of Regulation Z. §1026.4(a) states that a finance charge is the cost of consumer credit as a dollar amount. It includes any charge payable directly or indirectly by the consumer and imposed directly or indirectly […]