by georgeoself | BSA Compliance, Compliance, Cost of Non Compliance, Deceptive Advertising, Uncategorized, Unfair and Deceptive Bank Practice
Here’s a blinding glimpse of the obvious: there are a slew of marketing concepts that would be very attractive to bank customers. However, before a bank can kick off a new program, it needs to know if the new concept will comply with the State and Federal consumer...
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 | 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 | Compliance, Deceptive Disclosures, Uncategorized, Unfair and Deceptive Bank Practice
How’s a banker supposed to think about the regulatory expectation that banks educate their customers about online banking’s inherent risk? The regulators have definite expectations for banks who offer “eBanking” services. These expectations...
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...
