Archive

COMMUNITY BANK INFERIORITY COMPLEX

In my seminars and webinars around the US I frequently refer to the community bank inferiority complex. Many community banks feel that their compliance programs are not as good as programs at larger banks. My response to these laments is to point out that the primary difference between a community bank compliance program and the compliance program at a larger bank is that the larger banks tend to make larger mistakes. There is a never […]

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CFPB IS REVIEWING PREPAID CARDS

On May 23, 2012, the Consumer Financial Protection Bureau (CFPB) took the first step toward adopting consumer protections for the fast-growing prepaid card market. The Bureau’s Advance Notice of Proposed Rulemaking seeks input on how to ensure that consumers’ funds on prepaid cards are safe and that card terms and fees are transparent. The Bureau’s rulemaking will focus on “General Purpose Reloadable” prepaid cards which allow consumers to load the cards with money upfront and […]

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DISCRIMINATION AND THE LAZY BANKER SYNDROME

In a recent case the FDIC claimed a bank violated ECOA and Regulation B by engaging in a pattern or practice of denying applications for a credit card based on an initial match of applicant names to the Office of Foreign Asset Control’s list of Specially Designated Nationals (“SDNs”) without further verification that the applicants were in fact SDNs, which resulted in a disparate impact upon Hispanic applicants. The bank agreed to pay a civil […]

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CFPB RULES WILL SIMPLIFY/STRANGLE MORTGAGE POINTS AND FEES

On May 9, 2012 the Consumer Financial Protection Bureau (CFPB) outlined rules it is considering that would simplify (or strangle) mortgage points and fees. These rules, which the CFPB expects to propose this summer and finalize by January 2013, would make it easier for consumers to understand mortgage costs and compare loans so they can choose the best deal. The CFPB is considering proposals, required by the Dodd-Frank Wall Street Reform and Consumer Protection Act […]

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APPRAISAL SURVEY

Section 1026.41(f) of Regulation Z states, “The creditor and its agents shall compensate a fee appraiser for performing appraisal services at a rate that is customary and reasonable for comparable appraisal services performed in the geographic market of the property being appraised.” To assure the appraisal fee is “customary and reasonable” the creditor may either conduct its own appraiser survey or obtain a survey from a third party. In the past, several companies offer their […]

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