Everything old, is new again. In January 2020, the CFPB issued a policy statement on how it was interpreting and enforcing UDAAP. In March 2021 the new acting director of the CFPB announced a reversal of that position.
Electronic delivery can be your virtual friend before, during and after a pandemic. It helps the bank protect relationships, save time and money and satisfy customers who want information delivered quickly.
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.
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.
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.