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?
We found an HPML in our audit. There is no escrow set up. What can we do?
What is demonstrable consent and can we do that with new account disclosures we email the new customer?
Can we collect property taxes during construction based on the completed value of the home?
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?
How do we know when a cushion is allowed?
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>
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.
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?