As we approach the end of 2023, we wanted to take some time to reflect and comment on some of the most common lending missteps we’ve seen while performing audits for Clients during the year. TCA’s Top Five are firmly rooted in two regulations that examiners spend much time and focus on.
Regulation Z and the National Flood Disaster Protection Act.
Regulation Z has been around for a number of years and clearly underscores consumer protection by setting rules that protect consumers from paying more than was disclosed (APR/Finance Charge and Disclosure requirements), allow them time to contemplate the transaction (Rescission) and to fully understand the transaction they are entering (TRID). The National Flood Disaster Protection Act (Flood) is a perennial focus for examiners.
A pattern and practice of non-compliance with either of these regulations can result in customer restitution, regulatory criticism, and potential civil money penalties. Below are the most common missteps we’ve seen our clients have this year and the solutions we recommend.
TCA – A Better Way!
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