Archive

COMPLIANCE RISK – READING BUT NOT ACTING

In late 2017 the FDIC’s Dallas Region Quarterly Newsletter contained an article entitled Automated Overdraft Program and One-Time Debit and ATM Opt-In Procedure Considerations. The article described a situation observed in several examinations regarding overdraft programs and the interplay with Regulation E opt-in requirements. The well-written article concluded with the following admonition, “If you self-identify violations or potential issues described in this article, management should immediately modify procedures to prevent consumer harm, identify any customers […]

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FOLLOW-UP – COMPLIANCE REVIEW/AUDIT CONSIDERATIONS FOR 2014

We received some solid feedback to our recent article Compliance Review/Audit Considerations for 2014. Several readers thanked us for the article. Two reported that the 2014 review/audit was headed for “business as usual” until they inquired about the scope of the proposed review/audit and discovered Dodd-Frank was not included. One of the bankers is switching to another company for their 2014 and future reviews, reporting, “We have lost confidence in … (the name of their […]

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