CFPB - Changes to Notices/Signage?

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!

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?

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.

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

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.

AAN stuff says the same for non-CFPB regulated banks, correct?

Yes, except that the OTS went away.

Thanks Ted.

Correct. We fall into that category. What other signage aside from RBPNs need to be changed, or is there a list published somewhere?

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.

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.

Mine too!

Thanks folks. Now it's Tuesday... let's see how this day goes. Have a good one!