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Misleading Collection Scripts Cost Financial Institution $28.5 Million

10/18/2020

In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?

Option 1: CFPB Debt Collection Plan Doesn't Spare Community Banks

10/11/2020

In May 2019, the CFPB issued a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA); how has this rule updated the antiquated FDCPA? the NPRM will likely have a dramatic impact on collection practices for debt collectors.

Is Your Bank Affected By New Debt Collection Rules?

09/27/2020

For years, the Consumer Financial Protection Bureau (CFPB) has promised to prioritize rulemaking based on consumer complaints. The proposed rule was released in May 2019, but what effect, if any, does the proposed rule have on first-party creditors? What other regulatory concerns related to debt collection should my bank be aware of?

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E-Sign - Some Compliance Details

by Patti Joyner Blenden, President, Financial Solutions

UDAAP: The CFPB’s First Case

In its first significant enforcement action, the Consumer Financial Protection Bureau has issued a consent order against Capital One Bank.

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Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

How to Complete a CTR for Local Diocese

10/18/2020

A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?

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