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Exception Tracking Spreadsheet (TicklerTrax™)
Downloaded by more than 1,000 bankers. Free Excel spreadsheet to help you track missing and expiring documents for credit and loans, deposits, trusts, and more. Visualize your exception data in interactive charts and graphs. Provided by bank technology vendor, AccuSystems. Download TicklerTrax for free.

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CFPB Summer Supervisory Highlights

The CFPB has published [84 FR 49250] Issue 19 (Summer 2019) of its Supervisory Highlights, featuring findings in the areas of automobile loan origination, credit card account management, debt collection, furnishing of information to credit reporting companies, and mortgage origination identified in examinations that were generally completed between December 2018 and March 2019. More specifically, the report cites:

  • Automobile loan origination: Abusive acts or practices when selling add-on GAP products, such as selling such a product to consumers whose low loan-to-value meant they would not benefit from the product.
  • Credit card account management:
    • Failures to clearly and conspicuously provide disclosures required by triggering terms in online ads
    • offsets against consumers' deposit funds without sufficient documentation of the consumers' sufficient awareness of and intent to grant a security interest in those funds
    • deceptive threats of repossession or foreclosure in credit card collections
    • deceptive marketing of secured credit card accounts
  • Debt collection: False representation of the amount and legal status of debt
  • Furnishing credit information:
    • Failure to conduct an investigation or respond to a credit reporting company (CRC) after receipt of a dispute from the company
    • Failure to report to all applicable CRCs updates or corrections to information found to be incomplete following a dispute investigation
    • Failures to promptly send corrections or updates to all applicable CRCs after determining that previously furnished information about certain accounts was no longer accurate.
    • Failures of one or more furnishers of deposit account information to furnish updated information regard accounts that were paid in full or settled in full.
    • Failures by one or more furnishers of deposit account information to notify a nationwide specialty CRC that the information was disputed by consumers.
    • Failures to implement reasonable written policies and procedures regarding the accuracy and integrity of deposit account information it furnished to nationwide specialty CRCs
  • Mortgage origination: Inaccurate APR and Total Annual Loan Cost (TALC) disclosures in reverse mortgages
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