DISTINGUISHING “ABUSIVE” PRACTICES Many leading articles on the subject of the CFPB’s release of its position on “abusive” acts or practices proclaim that the CFPB has defined “abusive.” This is simply not true. The Dodd Frank Act already defined “abusive” …
WHAT’S IN YOUR LOAN REVIEW? Whether you’re a small community bank or a large regional bank, you should have a credit risk review function to analyze individual loan quality and to provide analysis of your entire portfolio quality. On October …
CRA TRACKING FOR PANDEMIC LOANS While we’re in the throes of the Covid-19 pandemic, the one thing we don’t need is more work. But it is an important season to think about how loan programs and modifications can work to …
SAVINGS ACCOUNTS AREN’T SAVINGS ANYMORE? When the FRB lowered required reserve requirements for checking and savings accounts to zero percent on March 26, it set off a host of questions about how that action affected checking and savings account definitions. …
The ATM – Automated Teller Machine – made its debut in 1967 at Barclays Bank in London. The first American version became available in 1969 at Chemical Bank on Long Island, NY. Initially, access was restricted to customers of the …
Evelyn I. Dehmey Evolution of the ATM: WHAT WILL MY ATM DO NEXT?
WHAT DOES CALIFORNIA LAW HAVE TO DO WITH THE EAST COAST? The California Consumer Privacy Act (CCPA) was signed into law on June 28, 2018 and becomes effective on January 1, 2020. This law has to do with creating new …
Evelyn I. Dehmey WHAT DOES CALIFORNIA LAW HAVE TO DO WITH THE EAST COAST?
Have you heard about the new registration requirements for Appraisal Management Companies? Effective August 10, 2019 all appraisal management companies (AMC) must register with the state or states in which they perform business and are subject to state supervision, if …
Appraisal Management Company Registration: Are You Aware? Evelyn I. Dehmey
We get questions from time to time as to whether a bank can target the geographic area around a branch, such as during a branch opening, or do a prescreened mailing to a group of people with particular characteristics. Of …
EGRRCPA – Let’s Take Stock! The “Economic Growth, Regulatory Relief, and Consumer Protection Act” was signed into law on May 24, 2018. It had many moving parts, some effective upon passage and others where regulations were first needed. Let’s explore …
Be Careful with That Online Account Opening! A year ago on May 24, 2018, EGRRCPA Section 213 authorized “Making Online Banking Initiation Legal and Easy” (MOBILE). The intent was to make online account opening easier and was effective immediately upon …
Be Careful with That Online Account Opening! Evelyn I. Dehmey