by georgeoself | Bank Compliance, Bank Customer Complaints, Compliance, Cost of Non Compliance, Deceptive Advertising, Deceptive Disclosures
Getting ready for your bank’s next consumer compliance exam will require a new, different mindset. Your bank can easily trip and fall over a practice you never noticed — much less thought of as “harmful.” To bankers who have recently been through this new...
by georgeoself | Bank Customer Complaints, Bank Security, BSA Compliance, Compliance, Cost of Non Compliance, Deceptive Advertising, Deceptive Disclosures, Unfair and Deceptive Bank Practice
The next big thing in bank compliance. You heard it here first: banks will be going on the offensive to solve their customer’s security problems by launching “Customer Security Portals” and “Customer Feedback Portals.” Banks are making...
by georgeoself | Bank Customer Complaints, Compliance, Deceptive Advertising, Deceptive Disclosures, Unfair and Deceptive Bank Practice
My grandfather used to say there were two damned lies. The first was told to children: “This hurts me more than it does you.” The second was, “The check is in the mail.” To this I add a third lie: “Your funds will be available in two...
by georgeoself | Bank Customer Complaints, Compliance, Cost of Non Compliance, Deceptive Advertising, Deceptive Disclosures, Reward Checking Account, Uncategorized
If you’re offering Rewards Checking accounts, you should take another look at your account disclosures. According to the FDIC, many banks are simply not being clear about exactly how the “reward” in Reward Checking can be earned. Frequently the...
by georgeoself | Bank Customer Complaints, Compliance, Deceptive Advertising, Deceptive Disclosures, FDIC Fees, Reward Checking Account, Uncategorized, Unfair and Deceptive Bank Practice
Providing disclosures in “fine print” may not be “fine” after all. Recently, many banks have been reacquainted by their examiner with Section 5 of the FTC Act: Standards of Unfair or Deceptive Acts or Practices. Section 5 deals with what is...
by georgeoself | Bank Customer Complaints, Compliance, FDIC Fees
You’re charging customers a “FDIC Fee?” Really? Still? In July 2012, the FDIC published FIL-33-2012. In that FIL, the FDIC made clear it was not going to be happy if it discovered an insured institution was attempting to pass along some or all of...