Deposits
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Credit Scores and Adverse Action Notices
When you use a credit score to deny a loan, your adverse action notice must include credit score information.
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UDAAP Violation Example
We recently spotted several potential Unfair, Deceptive or Abusive Acts of Practices (UDAAP) violations.
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Are You Independently Validating Your BSA/AML Software?
During Bank Secrecy Act/Anti Money Laundering (BSA/AML) exams, examiners are testing to see whether financial institutions had their transaction monitoring system independently validated.
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Obtaining Occupation at Account Opening
We occasionally find financial institutions not consistently obtaining the occupation of customers/members at account opening.
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Supreme Court Refuses to Hear CFPB Constitutionality Case
As reported in The Hill on January 14, 2019, the Supreme Court refused to hear a case involving the challenge to the constitutionality of the Consumer Financial Protection Bureau (CFPB).
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Bureau Issues Consent Order for Regulation E Violations
On January 3, 2019, the Bureau of Consumer Financial Protection (Bureau) issued a consent order against USAA Federal Savings Bank (Bank) for Regulation E violations.
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Deposit Insurance Fund Reserve exceeds The Minimum – I Smell Refund!
Small banks will receive a credit on their FDIC insurance premium. Check it out!
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Developing a Deposit Strategy? Do You Have an Industry-focused Approach?
Looking for deposits? Maybe this information will help.
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FinCEN Makes Permanent Beneficial Ownership Limited Exception
On September 7, 2018, the Financial Crimes Enforcement Network (FinCEN) made permanent the limited exception to the Beneficial Ownership Rule for certain products and services that were established prior to May 11, 2018.
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CFPB Finalizes Prepaid Rule Effective Date Extension
On April 20th the Consumer Financial Protection Bureau (CFPB) issued a final rule delaying the prepaid account rule effective compliance date 6 months