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SCRA – Who is a Servicemember
SCRA – Who is a Servicemember? If asked “Who is a Servicemember?” most compliance professionals might go the citation (50 USC 3911(1)) and read the definition of a Servicemember. Alternately, a compliance professional might say “We just query the Department of Defense...
The Abusive Standard “Extra A,” in UDAAP
CFPB has published a policy statement on the Abusive standard “Extra A,” in UDAAP. Consumer Compliance professionals who’ve been practicing their art since 2010 likely remember the day that “extra A” helped UDAAP become famous. That “extra A” was for the new Abusive...
Artificial Intelligence, Fair Lending, and UDAAP Walk Into a Bar
And just like that, Artificial Intelligence (AI) is striking up a bar fight. Thought leaders and industry trailblazers are starting to push back on the unregulated use of AI, partially due to the negative effects it could have on society. They might not be writing...
Dodd Frank Small Business Data Collection Final Rule will be Effective in Tiers
Acting on the directive in section 1071 of the Dodd Frank Act, the CFPB issued the final rule for the Small Business Lending Act on March 30, 2023, to implement the small business data collection requirements of section 1071. The intent – to provide insight into how...
Back to ERM Basics – ERM Policies
All regulatory eyes are back on Enterprise Risk Management (ERM) and executives at financial institutions can expect robust ERM exams in 2023 – no tea leaves required for this one. This article will look at the foundation of an ERM Program, meaning the ERM Policy. By...
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...