When your bank receives a claim that an ACH charge to a customer’s account was unauthorized, you have to respond correctly and your customer expects swift results.
It has been more than a few years since the Reg Z Loan Originator rules came about, and even longer since the SAFE Act requirements began. When rules and regs start to age, the rationale behind their policies and procedures are forgotten.
WednesdayApril 24, 2024
Common Compliance Violations, Enforcement Actions and Hot To
Nobody wants compliance mistakes but when they are tolerable and in moderation, you grow, you learn from them and that leads to improvement and survival in a tough world of compliance and banking.
Oil and water. Cats and Dogs. Fire and Ice. Such are the comparisons often used to describe the relationship between compliance and marketing. Are they really two opposing forces always in conflict and rarely compatible?
One banker commented “Reg E hasn’t changed, so what’s to learn?” While the Reg itself and the commentary haven’t changed, interpretations of who is a financial institution, what is an error and who has to investigate those errors have.
Nobody wants compliance mistakes but when they are tolerable and in moderation, you learn from them and that’s an improvement. Mistakes can be great when you learn from someone else’s because you don’t suffer the consequences.
The ATR / QM rule is approaching its 10th Anniversary. Somebody – maybe you – were involved in developing your bank’s program back in the day, but have you re-evaluated it since then?
It is a fact that, “you don’t know, what you don’t know.” But you will be responsible for all things compliance that you should know. You are responsible for ALL of the compliance changes, updates and guidance issued in 2022.
Do you ever feel at a loss for where to start in compliance research? Do you have an inkling the answer is out there somewhere, but you’d have better luck winning the lottery than finding the concise answer to that tough compliance question?