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.
TuesdayMarch 23, 2021
Regulation CC: Funds Availability (Deposits and Holds)
If your bank delays the availability of customer deposits, it needs to ensure that its Funds Availability Disclosures include the types of holds you may place and that the holds conform to the limits imposed by Regulation CC.
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.
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.