Ability-to-Repay Rule
2026-02-27 02:14:33
CTR Filing Threshold
2026-02-27 01:58:11
Investment Adviser Custody
2026-02-26 23:41:07
Resolution Plan Requirements
2026-02-27 00:22:54
SAR Filing — MSB
2026-02-27 02:01:18
SAR Filing — Banks
2026-02-27 01:44:29
Broker-Dealer Registration
2026-02-26 22:55:03
TILA — Definitions
2026-02-27 00:08:41
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40+ hours a week. Manual. Error-prone. One update in § 1010.311 cascades into 14 downstream rule changes no one catches until the enforcement action.
§ 1026.43 Minimum standards for transactions secured by a dwelling.
(a) Scope. This section applies to any consumer credit transaction that is
secured by a dwelling, as defined in § 1026.2(a)(19), including any real property
attached to a dwelling, other than:
(1) A home equity line of credit subject to § 1026.40;
(2) A mortgage transaction secured by a consumer's interest in a timeshare plan,
as defined in 11 U.S.C. 101(53D);
(3) A reverse mortgage subject to § 1026.33; or
(4) A temporary or "bridge" loan with a term of twelve months or less, such as a
loan to finance the purchase of a new dwelling where the consumer plans to sell a
current dwelling within twelve months or a loan to finance the initial construction
(b) Definitions. For purposes of this section:
(1) "Affiliate" means any company that controls, is controlled by, or is under
common control with another company, as set forth in the Bank Holding Company
Act of 1956 (12 U.S.C. 1841 et seq.).
(2) "Balloon payment" means a periodic payment that is more than two times a
regular periodic payment. A final payment is not a balloon payment if the loan
agreement requires at least one payment that is more than two times a regular
periodic payment and the final payment is no larger than such payment.
(3) "Business day" means a day on which the creditor's offices are open to the
public for carrying out substantially all of its business functions.
(4) "Covered transaction" means a consumer credit transaction that is secured by
a dwelling, as defined in § 1026.2(a)(19), including any real property attached to a
(c) Repayment ability; prepayment penalties—(1) Repayment ability.
Except as provided in paragraph (d) of this section, a creditor shall not make a
loan that is a covered transaction unless the creditor makes a reasonable and good
faith determination at or before consummation that the consumer will have a
reasonable ability to repay the loan according to its terms.
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12 CFR § 1026.43(c)(1)
Ability-to-Repay Determination
Creditor must make reasonable, good-faith determination that consumer can repay loan per its terms at or before consummation.
Verify ATR documentation before loan close. Mandatory for all covered transactions.
31 CFR § 1010.311(b)(2)
SAR Filing Deadline — Banks
SAR must be filed with FinCEN no later than 30 calendar days after initial detection of suspicious activity.
T+30 calendar day hard deadline from detection. File via FinCEN BSA E-Filing System.
17 CFR § 275.206(4)-2(a)
Custody Rule — Client Assets
Investment adviser holding custody of client funds without qualified custodian maintaining segregated accounts is per se fraudulent.
Qualified custodian required. Segregated account per client. Annual surprise exam unless exemption applies.
12 CFR § 252.82(a)
Resolution Plan — Tailored Approach
Covered companies may submit resolution plans under tailored approach if assets below $250B threshold.
Check consolidated asset threshold. Tailored plans due every 3 years vs. annual for full-resolution.
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