Refusing credit or increasing the rate because of an applicant’s race would be unfair. Holding deposits made by check for unreasonable periods of time without telling the customer the rules is unfair. Make sure marketing materials are reviewed under UDAAP standards before they are put before the public in any form. In the compliance world, we tend to focus on compliance with what is squarely in front of us. CFPB helps consumers complain by providing hints and topic areas on its website.
Home Newsletters Industry Resources Advertising. Defining what unfair or deceptive means has been the purview of the Federal Trade Commission. It may be good for the bottom line, but is it good for the customer? Lucy, a Certified Regulatory Compliance Manager, has over 30 years experience in compliance. In fact, it might even be the bow–the cross-bow. For example, Truth in Lending requires disclosure of the cost and terms of credit. More in this category:
Consumers are being encouraged to complain to CFPB about any situations where they feel unfairly treated.
Syudy are Banking Exchange contributing editors. When the pendulum swings For example, Truth in Lending requires disclosure of the cost and terms of credit. Compliance programs are designed to carry out everything that regulations require. UDAP has been a sleeper. The Equal Credit Opportunity Act bars discrimination on a prohibited basis.
From UDAP to UDAAP to ??
Why Apple and Amazon are Posi…. Third, pay close attention to customer complaints. There was plenty of noise about overdraft protection programs that should have warned banks about how the product was coming to be viewed. There may be a “free checking for life” promise lurking out there.
From UDAP to UDAAP to ?? – Banking Exchange
Make sure marketing materials are reviewed under UDAAP standards before they are put before stduy public in any form. Inevitable has finally happened What does this mean? The holder in due course rule only applied to sellers of goods or services who also provided financing.
For a long time, in the banking world, little happened. In the compliance world, we tend to focus on compliance with what is squarely in front of us. No thanks, I don’t want the latest banking news and analysis Already subscribed, please don’t show again.
One related to the “holder in due course” status of purchasers of commercial paper; one related to pyramiding late charges; and the third related to unfair contract terms. Are Financial Institutions Prepared to S….
I may unsubscribe caze any time. The FTC Act directed the financial regulatory agencies to apply those standards to actions undertaken by banks, thrifts, and credit unions. Latest from Lucy Griffin Regulatory relief: In all this focus on compliance with existing laws, we don’t always take a step back and consider the fairness of the products or services.
Holding deposits made by check for unreasonable periods of time without telling the customer the rules is unfair. The customer may not casf be right, but treat them as though they are. For example, if the bank decides to impose a monthly fee on checking accounts, consider how your customers will react to the fee.
Withholding this information would be unfair or deceptive. Dtudy fact, pay close attention to any customer feedback. Also look for any promises made to customers previously. This means checking off all the items for compliance before going to loan closing. Finally, remember the old saying about the customer.
It may be good for the bottom line, but is it good for the customer? Defining what unfair or deceptive means has been the purview of the Federal Trade Commission. More in this category: So how is CFPB really doing? It means setting up operating systems to do accurate calculations and complete disclosures.
Message to Small Banks: