04/17/2022
If UDAAP is going to be used to enforce “fair banking” will we see less of ECOA, the FHA and other anti-discrimination regs and laws?
03/27/2022
Are banks allowed to have referral programs for existing customers to refer new loan customers? If so, are the rules of such programs, and if not, what prohibits it?
03/20/2022
How much "teeth" does UDAAP really have to penalize a bank?
02/20/2022
I know blogs are popular for banks to use on their websites for connecting with customers and attracting new customers. While these do not fall into the traditional definitions of advertisements for disclosure purposes, do you see other banks including some type of disclaimer statement when a blog includes info such as steps to buying a home. For example, sharing info about credit score ranges, standard DTI ratios, money needed for down payment, etc.
I was thinking some type of disclaimer with the blog would be appropriate, such as: "Information regarding credit scores, debt ratios and other underwriting related information are examples only and do not represent the bank's exact underwriting criteria. All applications are subject to credit approval". Is there a best practice with blogs for referencing products and services in a generic manner?
01/30/2022
Is a person’s written consent required for us to access their credit bureau file?
01/01/2022
Is a person’s written consent required for us to access their credit bureau file?
12/26/2021
Is redlining real? It seems to be an antiquated type of violation.
12/19/2021
Why am I concerned with the FDCPA since it applies to third party collectors?
12/19/2021
Why am I concerned with the FDCPA since it applies to third party collectors?
08/08/2021
If we have a rate sheet that we give to real estate agents and our loan originators, but we know the true use will be for them to hand it to consumers or post it where consumers can readily access it, wouldn't we need to have the APR on it?