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...
by georgeoself | Uncategorized
UDAAP Is Changing Perspective on Compliance Starting now, banks have to look at compliance through the lens of consumer satisfaction. Model forms and correct disclosures are no longer all that is needed. UDAAP is a game changer for financial institutions. The...
