Most Popular Compliance Content
Threshold for UW and Pricing Exceptions
03/31/2019
What is a reasonable threshold for UW and Pricing Exceptions for fair lending monitoring? is a 10% threshold reasonable ?
Tracking complaints is required
03/31/2019
What might happen if we don't have a system to track complaint resolutions?
LOC to Secure Bond for Residence Purchase Purpose
03/31/2019
Is Letter of Credit to secure a Bond for the purpose of purchasing a residence HMDA reportable?
Reg E Type of Transfer/Type of Account
03/24/2019
Under Regulation E, section 1005.9(b), Banks are required to include the type of transfer and the type of account to or from which the transfer was made. The commentary doesn't specify how you disclose the type of account under this section (however, it does specify how to disclose this for terminal receipts under 9(a)). So, my question is, is it OK that our periodic statements just state "transfer from account XXXX" instead of specifying the account type or should it be stating transfer from checking/savings?
Customer Wants to Apply for Higher Rate for CC
03/24/2019
If a consumer has a rate on a specific credit card and voluntarily chooses to apply for a higher rate card product with the same institution, does the institution have to protect the lower balance at the lower rate or because the consumer asked for the new higher rate product can the entire balance be moved to the higher interest rate? So say a non rewards card and the consumer wants a rewards card and they agree to moving the existing balance over to new rewards product.