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”.
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
Websites are not a secondary means of advertising or information delivery. Risks are increasing as banks increase the functionality of their sites and customers go to their web addresses more than their branches.
Subpoena? Don’t freak out! When you receive a subpoena or other legal process, you need to methodically move through a framework for analysis that will aid you in determining what you need to do and how to do it.
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.