The bank is considering a credit card promotion for a period of 90 days that will waive the annual fee for the life of the credit card. A customer must apply for the credit card during this time frame to be eligible. It will not be advertised externally. Must the credit card application be altered or can we leave the annual fee on the app in case other customers take the application with them? What other compliance requirements exist for this type of promotion?
Is there any standard format to send notice of a change in terms for credit cards?
During the PPP loan programs we had many requests, but we were not participating? These are commercial requests and would be subject to Reg B. Were adverse action notices required?
Are rate sheets we send to auto dealers and mortgage brokers CAN-SPAM covered?
We are just a mortgage lender, does this CAN-SPAM affect us?
What is a MAPR?
A soldier’s mother called to tell us her son joined the Army. Do we have to reduce the loan rate that day?
If our borrower hasn’t requested SCRA protection and is past due on her mortgage, can we start foreclosure as we normally would?
We received a complaint from an account holder who used their credit card to purchase a trip on 7/3/18 for over $2,600 from a travel company. He
provided evidence to us on 8/11/18 that the travel company had closed and the trip would not be offered and there would be no refund for what he had
paid. The information he was provided from the travel company said the purchase was non-refundable and he had not purchased trip cancellation
protection. He filed a dispute with us on 8/11/18 asking for credit for the cost of the trip. He did not make any payments on the account between
7/3/18 and 8/11/18, so it seems to me he would have a valid claim under both Reg. Z 1026.12 and 1026.13 (since he didn't/isn't going to receive the
services he paid for and he filed his dispute within 60 days of the date of the statement the charge appeared on and he had not paid for the charge
before he filed his dispute. Our bank's disputes department declined his claim, so he filed subsequent disputes, but was told each time that he was
not entitled to a credit. I work in Complaints, which is where this claim has now landed, and I believe we need to credit him for the purchase. Is my
The Military Lending Act does not specify if the Act applies to an open-ended Overdraft Protection line that is tied to a checking account or a closed-ended loan secured by the applicants’ deposit accounts such as a savings and/or certificate of deposit. Does the Rule apply to both consumer credit types?