One of the most severe penalties from a pattern of MLA violations was having a CRA rating downgraded and it just recently happened. The Military Lending Act and especially the Servicemembers Civil Relief Act are still hot issues.
There was a headline which read, “Big Bank Pays $15.5M Penalty for Reg E Violations.” It wasn’t all claims related but fines for that were included in the total penalty.
On-Demand Webinars about Audit and Internal Controls
Mistakes are good when you learn from them. Mistakes are great when you learn from someone else’s. Join me as we look at what examiners are finding wrong in banks so they do not find it wrong in yours.
It’s a fact of life, “you don’t know, what you don’t know.” Unfortunately, that never means you are not responsible for ALL of the compliance changes, updates and guidance that were issued in 2020.
One recent court case held that disclosures on a website were not conspicuous because it was not set apart from other text sufficiently and other distractions on the page drew away the readers attention.