On January 2, 2019, Kathleen Kraninger of the CFPB entered her first Consent Order with USAA Federal Savings Bank, an $80 billion institution based in San Antonio, TX. USAA had Regulation E violations related to: Failing to properly stop preauthorized …
Evelyn I. Dehmey What Can We Learn from the USAA Regulation E Case?
PREPAID ACCOUNTS RULE – DOES THIS AFFECT OUR BANK? The Prepaid Accounts Rule has been delayed so many times that Compliance Officers have almost forgotten about it. The initial final rule was first published on October 5, 2016, delayed on …
When the FACT Act was rolled out, it took 3 years for regulators to fully implement it with regulations. It seems when we hit the “Identity Theft” sections, it took our breath away and most institutions left their focus there. …
Evelyn I. Dehmey What Can We Learn from the State Farm Case?
WHAT HAPPENED TO ETHICS? Recently, the FDIC softened its approval for Section 19 approvals which is required to insure a person is employable in the financial services industry. Section 19 prohibits a person convicted of any criminal offense involving dishonesty, …
Privacy Fallout Everyone’s been waiting a long time for the CFPB to make the FAST Act rule concerning annual privacy notices “official” by way of regulation. Well, that happened on August 17, 2108 but there are still a few caveats. …
How does Pennsylvania’s New iLottery Affect Financial Institutions? On June 4 the Pennsylvania Lottery launched interactive games played online – computer, tablet or mobile devices – for chances to win up to $250,000. Players must first sign up for an …
Can I Stop Collecting Expanded HMDA Data? On July 5 the CFPB issued a press release announcing the partial exemption for institutions who originated fewer than 500 closed-end or 500 open-end lines of credit in the preceding two years. Since …
CDD/ Beneficiary Ownership – CD (Renewal) Dilemma Until April 3rd, institutions were allowed to risk-rate “triggering events” that would stimulate the new beneficial ownership certification. At the 11th hour, FinCEN published its beneficial ownership FAQ and sent the banking world …
CDD/ Beneficiary Ownership – CD (Renewal) Dilemma Evelyn I. Dehmey
Does a Creditor Need to Share Closing Disclosures with Third Parties? Often times as a settlement is coming down to the wire, there are pressures to share the Closing Disclosure with a realtor or broker involved in the transaction. Why …
Does a Creditor Need to Share Closing Disclosures with Third Parties Evelyn I. Dehmey
Credit Reports and Public Records As a result of a settlement between the three national consumer credit reporting companies and 30 state attorneys general (National Consumer Assistance Plan or NCAP), the credit bureaus were required to increase the accuracy of …