It has been more than a few years since the Reg Z Loan Originator rules came about, and even longer since the SAFE Act requirements began. When rules and regs start to age, the rationale behind their policies and procedures are forgotten.
WednesdayApril 24, 2024
Common Compliance Violations, Enforcement Actions and Hot To
Nobody wants compliance mistakes but when they are tolerable and in moderation, you grow, you learn from them and that leads to improvement and survival in a tough world of compliance and banking.
All too often the person(s) conducting robbery training or handling the aftermath of a robbery have very little background in the area. A majority of the time they have never experienced a robbery or been involved with the aftermath.
Financial institutions that are not prepared for an internal embezzlement will make major mistakes. Fraud can be easy to find when only one person is involved.
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”.