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”.
Call it S.2155, Economic Growth, Regulatory Relief and Consumer Protection Act, EGRRCPA, or Public Law No: 115-174, deregulation by any other name is just as sweet. The sour part is, deregulation will be more work in the short run.
What you don’t know about Cyber Incident Response can cause more risk and damage than the incident. Cyber-attacks affect the entire bank and every function; it’s not just an I.T. problem. Successful response plans go beyond technology.
The Real Estate Settlement Procedures Act (Regulation X) has contained rules for administering escrow accounts for many years. The Truth in Lending Act (Regulation Z) requires escrow accounts in connection with higher-priced mortgage loans.