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#1752250 - 10/25/12 01:52 PM CFPB - Changes to Notices/Signage?
YosemiteSamIAm Offline
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In addition to the address changes we have to make to the adverse action notice and the RPBN/exception notices, what other notices and/or signage needs to be updated? I realize that our lobby posters need to be changed as well. Anything else I am missing? Thanks!
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#1752883 - 10/26/12 05:46 PM Re: CFPB - Changes to Notices/Signage? YosemiteSamIAm
Combustible Offline
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Nice question Yosemite--I must have been napping and missed the required address changes. When is this required to change, and is this only for all sized banks?

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#1752914 - 10/26/12 06:45 PM Re: CFPB - Changes to Notices/Signage? YosemiteSamIAm
Dan Persfull Offline
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It's my understanding those changes only apply to FIs that will be regulated by the CFPB which are those FIs of $10 billion or more in assets.
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#1752924 - 10/26/12 06:56 PM Re: CFPB - Changes to Notices/Signage? Dan Persfull
Ted Dreyer Offline
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The RBP changes apply to all RBP notices even if you are not supervised by the CFPB. The model notices were changed some time ago, but the instructions allow either the old language or the new language to be used until 1/1/2013. See instruction 3(a)(ix): http://www.bankersonline.com/regs/12-1022/12-1022-apph.html

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#1752932 - 10/26/12 07:14 PM Re: CFPB - Changes to Notices/Signage? YosemiteSamIAm
Dan Persfull Offline
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Thanks Ted. I overlooked that so now I will add it to a follow-up list with my vendor to insure they get it changed.
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#1752944 - 10/26/12 07:33 PM Re: CFPB - Changes to Notices/Signage? YosemiteSamIAm
raitchjay Online
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OK
AAN stuff says the same for non-CFPB regulated banks, correct?
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#1752979 - 10/26/12 08:40 PM Re: CFPB - Changes to Notices/Signage? raitchjay
Ted Dreyer Offline
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Yes, except that the OTS went away.

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#1752981 - 10/26/12 08:42 PM Re: CFPB - Changes to Notices/Signage? YosemiteSamIAm
raitchjay Online
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OK
Thanks Ted.
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#1753121 - 10/29/12 03:07 PM Re: CFPB - Changes to Notices/Signage? Dan Persfull
YosemiteSamIAm Offline
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Originally Posted By: Dan Persfull
It's my understanding those changes only apply to FIs that will be regulated by the CFPB which are those FIs of $10 billion or more in assets.
Correct. We fall into that category. What other signage aside from RBPNs need to be changed, or is there a list published somewhere?
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#1753484 - 10/30/12 05:28 PM Re: CFPB - Changes to Notices/Signage? YosemiteSamIAm
Patricia Offline
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Appendix A to Part 1002 states that only banks, savings associations and credit unions with total assets of over $10 billion and their affiliates would use the Bureau of Consumer Financial Protection for Adverse Action Notices.

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#1755152 - 11/05/12 08:05 PM Re: CFPB - Changes to Notices/Signage? Patricia
SunnyFL, CRCM Offline
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You can certainly tell its Monday.... having a little trouble following this thread.... If you are NOT supervised by the CFPB, you do not use their name and address on Adverse Action Notices but you would use their name and address on RBP Notices?

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#1755169 - 11/05/12 08:26 PM Re: CFPB - Changes to Notices/Signage? SunnyFL, CRCM
Tesla Offline
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Originally Posted By: SunnyFL
You can certainly tell its Monday.... having a little trouble following this thread.... If you are NOT supervised by the CFPB, you do not use their name and address on Adverse Action Notices but you would use their name and address on RBP Notices?


That is my understanding. smile
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#1755204 - 11/05/12 09:14 PM Re: CFPB - Changes to Notices/Signage? Tesla
Ted Dreyer Offline
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Originally Posted By: Tesla
Originally Posted By: SunnyFL
You can certainly tell its Monday.... having a little trouble following this thread.... If you are NOT supervised by the CFPB, you do not use their name and address on Adverse Action Notices but you would use their name and address on RBP Notices?


That is my understanding. smile


Mine too!

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#1755292 - 11/06/12 01:16 PM Re: CFPB - Changes to Notices/Signage? Ted Dreyer
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Thanks folks. Now it's Tuesday... let's see how this day goes. Have a good one!

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