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?
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>
If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?
Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?
Most restaurants offer senior discounts now at about age 55 and so we want our Seniors Checking account product to be available at age 55. Our compliance officer said it violated Reg B, but then left the bank. This isn’t a loan product, so what gives?
If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?
Has there been a case where a lender tried so hard to assist minority applicants that it had a fair lending issue with majority applicants?
Is CAN-SPAM consumer protection and limited to consumers?