Archive

CFPB PROPOSES CHANGES TO REMITTANCE TRANSFER RULE

The Consumer Financial Protection Bureau (CFPB) has issued a Notice of Proposed Rulemaking (NPRM) related to the Remittance Transfer Rule implemented in Regulation E (Electronic Fund Transfers Act). The Remittance Transfer Rule establishes protections for consumers sending international money transfers or remittance transfers by requiring remittance transfer providers to disclose the exact exchange rate that applies, the amount to be received by the recipient, and certain fees and other information associated with the transfer. The […]

Read More…

PREPAID ACCOUNTS – EXAMINATION PROCEDURES

The Federal Deposit Insurance Corporation has released examination procedures for Prepaid Accounts to incorporate the Consumer Financial Protection Bureau’s (CFPB) amendments to Regulation E and Regulation Z. The examination procedures may be helpful to financial institutions seeking to better understand how examiners will evaluate an institution’s compliance with the prepaid account rule.. On October 3, 2016, the CFPB published its Final Rule for Prepaid Accounts to create comprehensive consumer protections for prepaid accounts. Specifically, the […]

Read More…

USAA ENFORCEMENT ACTION

When a big bank gets hit with a big penalty I often find that community banks think it is a “big bank thing” that does not impact community banks. Big banks make the same mistakes as community banks but they do it on a bigger scale. The recent settlement between the Consumer Financial Protection Bureau (CFPB) and USAA Federal Savings Bank (USAA) is a good case in point. The CFPB found that USAA: Violated the […]

Read More…

PREPAID RULE LIVES TO FIGHT ANOTHER DAY

For those banks that fervently prayed the almost 1,700-page Prepaid Account rule would be banished by the Party of Lincoln – sorry but it survived the recent round of regulatory rollbacks.  Courtesy of the law firm, Ballard Spahr, and its Consumer Finance Monitor (CFM) webpage and Politico, we have learned that the joint resolutions introduced in the Senate and House in February to kill the upcoming Prepaid Account regulation, died on the vine of apathy.  […]

Read More…

REGULATION E ERROR RESOLUTION AND POLICE REPORTS – NEITHER THE TWAIN SHALL MEET?

During a recent Regulation E training event, the class and I discussed the Regulation E Section 1005.11 “Procedures for resolving errors” and there, as always, was very active discussion of what a bank may request, but not require. I brought up the prohibition against requiring police reports as a requirement for the bank to either begin the investigation provision or to provide provisional credit and there were a number of questions.  Many banks have in […]

Read More…