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.
Paraphrased, here is what one circuit court said, “consumers are protected from a company’s deception, even if they never actually read its disclosures.” The world of compliance is different when you consider UDAAP whether with one or two “A’s”.
Recorded on April 11, 2018
New Mortgage Servicing Rules – Successors in Interest and Bankruptcy
Is this a Rollover? Is this a Transfer? Can I quit my job now???!!! Many banks underestimate the importance of know the difference between an IRA Rollover and an IRA Transfer. Does it make a difference?
FinCEN says that “Banks specifically are expected to “obtain information at account opening sufficient to develop an understanding of normal and expected activity for the customer’s occupation or business operations.” In short, to understand the typ
Don’t wake up in a cold sweat worried that some lending compliance changes have escaped your notice! Tune in to this program for a quick rundown of what’s new, what’s changed, what you need to watch out for.