In March 2022 the CFPB announced it would be targeting unfair discrimination in consumer finance. You have likely heard and may have even said, “there is no fair lending equivalent for deposits.” Well – now there is.
One banker commented “Reg E hasn’t changed, so what’s to learn?” While the Reg itself and the commentary haven’t changed, interpretations of who is a financial institution, what is an error and who has to investigate those errors have.
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.
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.