What’s the most severe penalty for a military lending violation you’ve seen?
What action steps are needed when we find a severe or frequent violation?
Why is a permissible purpose needed to get someone’s credit report?
Our FI is planning on using Promontory to offer broker deposits to consumers.
I have thought that Reg DD, section 1030.4 thru 1030.6 (Account
Disclosures) apply, however the Agreement and periodic statement don't specifically
address by Reg DD the required elements. For example, their Agreement states
accrued interest will be credited "at least once each month" vs. a specific
frequency, and it does not reference if accrued interest will be paid or not
paid if the account is closed, and refers to the APYE as "Statement Period
We have just received communication from the vendor and they are telling us
that "A Relationship Institution is a “deposit broker” for purposes of
TISA and, as such, is subject only to the advertisement provisions of Reg
DD." But they don't even spell out at least once Annual Percentage Yield.
Is our FI required to meet all the requirements of Reg DD as if the consumer
were opening one or our MMAs?
Is there an FDIC requirement that the "Member FDIC" logo be on all our pages and link to the FDIC website?
We include the EHL logo on our website where we offer home loans. We also use Twitter and Facebook, but do not use it there because it is on our site. Are we OK?
Is the term “Equal Housing Lender” on our website sufficient or should we actually have the “Dog House” logo?
Do weblinking rules apply if a business has a link to us, and are we required to monitor this?
We currently keep both electronic copies and paper copies of every change made on our website. This is time-consuming to maintain. How critical is it to keep hard copies of our work, and what questions should we be asking ourselves to potentially reduce or eliminate unnecessary paper trails?
What is demonstrable consent and can we do that with new account disclosures we email the new customer?