Skip to content
BOL Conferences
Thread Options Tools
#1681899 - 03/23/12 09:10 PM Information Security and UDAAP
SUSANE1 Offline
Platinum Poster
Joined: Mar 2008
Posts: 808
Reading a compliance article that said bank was cited for UDAAP relating to their information security program. Also in the area of Reg E error resolution. The article did not give specifics in the info security matter. Have others heard why?

Return to Top
General Discussion
#1681909 - 03/23/12 09:19 PM Re: Information Security and UDAAP SUSANE1
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,965
Illinois
I can't answer to the info security, but the Reg E citations were in relation to improper disclosure of an overdraft program and requiring police reports as a condition of opening a Reg E investigation.

Related Thread
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#1681922 - 03/23/12 09:30 PM Re: Information Security and UDAAP SUSANE1
SUSANE1 Offline
Platinum Poster
Joined: Mar 2008
Posts: 808
The Reg E citation pointed to error resolution and inconsistencies between bank's practices, and its disclosures, such as a teller or customer service telling a customer they needed to go to the merchant first before following through on a error resolution claim........ REg E disclosure said investigation would begin upon notice from customer -- therefore customer was "deceived".

Return to Top