For example, if the bank decides to impose a monthly fee on checking accounts, consider how your customers will react to the fee. The customer may not always be right, but treat them as though they are. Then along came some credit card marketing practices that simply could not be ignored. Latest from Lucy Griffin Regulatory relief: How could you stop it in your bank? Does the customer know everything they should know before making a decision?
Dancing With the SARs. Lucy, a Certified Regulatory Compliance Manager, has over 30 years experience in compliance. Everything will be evaluated in the context of fairness to the customer, rather than simply technical compliance. The latter two rules were re-issued by the Fed and NCUA because they specifically relate to credit practices. CFPB helps consumers complain by providing hints and topic areas on its website.
Lucy, a Certified Regulatory Compliance Manager, has over 30 years experience in compliance. Refusing credit or increasing the rate because of an applicant’s race would be unfair. No thanks, I don’t want the latest banking news and analysis Already subscribed, please don’t show again.
From UDAP to UDAAP to ?? – Banking Exchange
So how is CFPB really doing? There may be a “free checking for life” promise lurking out there. The Equal Credit Opportunity Act bars discrimination on a prohibited basis.
When the pendulum swings Defining what unfair or deceptive means has been the purview of the Federal Trade Commission.
Also look stuudy any promises made to customers previously. Providian became the poster child for UDAP. There was plenty of noise about overdraft protection programs that should have warned banks about how the product was coming to be viewed.
Inevitable has finally happened What does this mean?
The FTC Act now prohibits unfair, deceptive, or abusive trade practices. In the Dodd-Frank Act, “abusive” was added to the list of prohibited trade practices. Second, make sure that UDAAP issues are considered in all new product development and in product changes. Both are Banking Stidy contributing editors. The holder in due course rule only applied to sellers of goods or services who also provided financing.
Everything will be evaluated in the context of fairness to the customer, rather than simply technical compliance.
First, focus on marketing. Both of these situations could have been anticipated and additional regulation averted if the industry had self-examined using UDAAP-style standards. What does this mean? Complaints about lengthy holds resulted directly in legislation regulating holds. I may unsubscribe at any time.
Dancing With the SARs.
Holding deposits made by check for unreasonable periods of time without telling the customer the rules is unfair. More in this category: Home Newsletters Industry Resources Advertising.
From UDAP to UDAAP to ??
How could you stop it in your bank? Why Apple and Amazon are Posi…. UDAP has been a sleeper. She is also editor of Compliance Action newsletter and senior advisor with Paragon Compliance Groupa compliance training firm.
Then along came some credit card marketing practices that simply sudy not be ignored. In fact, pay close attention to any customer feedback. Are Financial Institutions Prepared to S….
In fact, it might even be the bow–the cross-bow.