09/29/2024
Who is an “Executive Officer” under Reg O?
09/22/2024
An auditor just told us we have an APR violation on a TRID loan, and we need to make restitution to the borrower. Don’t we need to send a corrected Closing Disclosure too?
09/15/2024
Does UDAAP apply to just consumers, or all customers?
06/16/2024
I’ve been hearing about the new $8 cap on credit card late fees. My bank offers cards issued by an agent bank, but the card shows our bank logo and we hand out brochures for the product. Will our customers be impacted?
06/09/2024
My boss told me today our bank is seriously considering doing an in-house credit card program. HELP! I don’t even know where to begin. What should I expect and where can I learn more?
06/02/2024
We have a credit card product that has an introductory “fixed” rate that changes after 12 months to a variable rate APR. Management wants to really promote that fixed rate period, but I don’t think we can use the word “fixed”, can we?
05/26/2024
My bank just received an SCRA request for rate relief on a customer’s credit card line. The card normally has a 22.99% interest rate, so 6% is a big drop! How do we do it? Is it only on existing balances up to this point, or does it need to remain at 6% for all past and future transactions, until his active duty ends?
05/19/2024
In terms of UDAAP, what makes something “Abusive”?
05/19/2024
Does the FFIEC APR Calculator work for HELOCs?
05/19/2024
My bank has just acquired another bank that has its own in-house credit card program. We’ve purposely never done an in-house credit card program because of the sizeable compliance burden of them, but now here we are. What do I need to know for compliance on these acquired cards?