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.
We had a customer ask to start a voluntary escrow account on an existing loan. Do we need a new agreement?
In the August 30, 2020, Weekly Banker Briefing there was a question regarding receiving scanned driver's licenses when customers open accounts online. The last sentence of the response said the financial institution must delete the copy or image after use. I don't see that in section 213 of the Economic Growth, Regulatory Relief and Consumer Protection Act. Where can I find information regarding the requirement to delete the image? https://www.bankersonline.com/qa/scanned-drivers-licenses-it-legal
What does it mean to “automatically clear” exceptions?
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?