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CFPB Debt Collection Plan Doesn't Spare Banks

04/28/2019

On October 17, 2018, the CFPB announced that it plans to issue a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA) this spring; the NPRM will likely have a dramatic impact on collection practices for debt collectors. But, what affect, if any, will it have on first-party creditors? What other regulatory concerns related to debt collection should my bank be aware of?

Misleading Collection Scripts Cost Financial Institution $28.5 Million

04/21/2019

In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?

Misleading Collection Scripts Cost Financial Institution $28.5 Million

04/14/2019

In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?

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Extended OFAC records retention period

03/16/2025

My question is about the new OFAC retention rules effective March 12, 2025. What records are covered? Will OFAC checks at new account opening need to be kept 10 years now or is the new rule just for hits and blocked property?

Telephones in Vaults

03/16/2025

Is it still a good practice, or industry standard, to have a telephone hidden in the cash vault? We recently revamped our phone system, and in the process, most of the vault phones in our 8 branches were disconnected. Nobody checked with the Security Officer, they just determined that the phone lines in question didn’t have any history of being used, so they got disconnected. I recently did a Security Officer walk through of all the branches and discovered the vault phones were not working. My recommendation was to hook them back up and I’m getting push back because of the cost.

Debit card logistics for banks without deposit account

03/09/2025

I have two questions relating to debit cards: 1. Does a bank have to have an ABA routing number for debit cards to function? 2. Are banks with no public depositor service able to use internal accounts as private checking accounts with debit cards to pay bank taxes and order supplies?

Sole proprietor changing to LLC

03/09/2025

We have a sole proprietorship DBA account under a Social Security number. The customer now has an LLC with an EIN. Do I need to change the account number or just update the signature card to reflect the LLC as the Primary and remove the DBA on the account?

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