What kinds of fines or penalties would an institution face from regulators for sending out letters of resolution well past the extended 90 day timeframe??

Thanks,

Duke

You mean for Reg. E claims?

The horse is out of the barn. All you can do is fix it and prevent it from happening again. I doubt you'd see any CMPs. It might be written up in the exam report, depending on the circumstances. But if you found it, reacted to it, corrected it and have placed new steps to prevent it, you may get away with nothing but the knowledge that your compliance program is working.

If you flat out didn't pay claims, the same may apply but you've now encroached on customers rights and remedies. Here again, depending on the severity and circumstances, catching and correcting is all you can do. It won't look good, but it isn't a killer and likely isn't a CMP either.

Sorry, yes, I meant for Reg. E claims.

Thanks for the response, Andy!