Regarding Risk Based Pricing Notices - what was the date to switch from Fed & FTC web site information provided on the notice (How can you get more information?) to the CFPB web data?
Will the address of the CFPB be required on all ECOA Notices beginning on January 1, 2013?
Have the new UDAAP requirements been published? When are these requirements supposed to be effective? If they are already in effect, where could I find the text?
Does the FACT act apply to commercial loans?
A customer has opted in to the overdraft protection and then the bank decided to suspend his protection because he did't bring his account positive. Is there a disclosure the bank needs to send to the customer letting him know that his overdraft protection has been suspended? If the bank wants to reinstate the overdraft protection after the account is brought current, does the customer need to sign the opt-in form again?
During a recent FDIC exam, we were advised it would be a violation to use medical collections as a negative basis for a credit decision since that constituted "use of medical information." I reviewed the FACTA and commentary from the FTC which does not seem to support the statement from the examiner. As a general rule we would not view a few small medical collections as significant credit issues. However, if there are many unpaid medical collections or they are large amounts, it could negatively affect a credit decision in the same manner as any other non-medical collection would. It is hard for us to accept that evaluating an unpaid medical collection constitutes "use of medical information." What is your opinion?
We would like to train our tellers on cross selling bank products. What are some compliance issues that the tellers need to be aware of when mentioning various products to customers?