by georgeoself | Bank Compliance, Compliance
In the new world spawned by Dodd-Frank and the CFPB, community banks need to exploit every possible revenue possibility. Not all, by any means, are viable. Of those that are, bank management needs the help of compliance people who have more to offer than knee-jerk...
by georgeoself | Bank Compliance, Unfair and Deceptive Bank Practice
Community Bank CEOs now joined at the hip with their Compliance Officers? Yep, and it happened on November 16, 2013. That’s the day the Fed published its new consumer compliance “Risk-Focused Examination Program.” That would be RFEP to you. The ties...
by georgeoself | BSA Civil Money Penalty, Compliance, Cost of Non Compliance, Uncategorized
I don’t care how big you are, a $10 million CMP is serious money. TCF Financial Corp. will pay $10 million for lapses in monitoring suspicious bank transactions, including potential terrorist financing. According to reports in The Star Tribune, the fine...
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...
