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Unfair, Deceptive, Abusive Acts and Practices (UDAAP) – You Need to Do the Math Pt. II
Imagine a consumer not being able to recalculate a fee on their monthly deposit account statement based on the information in the statement? It could happen, and it could be a UDAAP as well as a violation of Truth-In-Savings (TISA) Regulation DD. Assume Bank XYZ has a...
Reviewing for Potential UDAAP Issues
Reviewing For Potential Unfair, Deceptive, Abusive Acts and Practices (UDAAP) Issues: On March 8, 2023, the CFPB issued a special edition of their Supervisory Highlights publication to highlight issues noted at financial institutions and servicers regarding junk fees....
FDIC Chairman Martin Gruenberg- What the Remarks Mean to You
What the FDIC Chair’s Remarks Mean to You: What’s old is new again On March 6th FDIC Chairman Martin Gruenberg’s remarks at the Institute of International Bankers Washington Conference focused on the challenges ahead in the banking industry. Although he ended his...
Fair Lending Nuances in Consumer and Residential Loan Servicing – pt. III
Fair Lending is on every compliance examiner’s radar, and nowhere is this more apparent than in examinations of consumer and residential loan servicing. Read any issue of the CFPB’s Supervisory Highlights and note how many examples deal with consumer and residential...
Hot Topics in Fair Lending pt. II- Appraisal Bias
In Part I of this multi-part Fair Lending article, we considered the topic of Redlining. In Part II, we’ll consider one of the newer Fair Lending hot topics – Appraisal Bias. Appraisal Bias is the practice of an independent appraiser placing a value on a property...
Hot Topics in Fair Lending – The Secret Sauce is in your REMA
Ask any lending compliance officer in a financial institution what keeps them up at night lately, and their reply will probably have something to do with Fair Lending – specifically redlining, and the new issue, appraisal bias. This multi-part article will consider...