Latest Operations - Real Estate Lending Topics

“One-click away” disclosure rule

09/08/2019

What is the “one-click away” rule for electronic advertisements?

Privacy among applicants

06/03/2019

If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?

Discrimination against the majority

05/26/2019

Has there been a case where a lender tried so hard to assist minority applicants that it had a fair lending issue with majority applicants?

AAN? We don’t make those loans.

05/19/2019

Our lender had a request for a reverse mortgage. He provided an Adverse Action Notice, but did he have to, since we don’t offer reverse mortgage loans?

‘Click me to enroll’ isn’t enough

04/28/2019

Our customers who want e-disclosures click on an “Enroll Me” link. Is that good enough for compliance?

Current Bureau Hot Topics

04/07/2019

Based on the CFPB's latest semiannual report, what are examples of topics of critical importance to the Bureau right now?

Who opens e-statements and who doesn’t

04/07/2019

If we send e-statements are we required to monitor whether they are being read, and if the customer is not opening them, do we have to revert back to paper?

Complaint retention

03/24/2019

How long should we keep typical complaint letters?

E-SIGN and demonstrable consent

03/24/2019

We like having customers sign up for Internet banking when they open their accounts. Is this acceptable for E-SIGN, or is more needed?

Complaint responses scripts

03/03/2019

Do you recommend having scripts to respond to complaints received over the phone and do you recommend taping the conversations?