One of the more difficult tasks that our clients must accomplish is to try to meet the community development and community service tests in the Community reinvestment Act (“CRA”). For many community banks the opportunities to do community service that qualifies under the requirements of the CRA are very limited.
The regular review of the declines and withdrawals is a common practice at financial institutions. In fact a secondary review of decline notices and withdrawals is a standard part of a strong compliance management program. The typical review includes making sure that notices are given on a timely basis, to the appropriate parties and that the notices include the proper reasons for the declination.
There has been a great deal of attention paid to the idea that the TILA / RESPA Integrated Disclosure Rules (“TRID”) will soon be implemented. These rules combine the Good Faith Estimate from RESPA and Truth in Lending disclosures from Regulation Z which are both currently required for a mortgage loan. Information that fully describes the requirements of these rules is readily available.