May 31

Recent Compliance Issues: 5/13/16 – 5/26/16


1. On Wednesday, May 18, 2016, the Consumer Financial Protection Bureau (CFPB) and four, federal, financial, regulatory agencies issued guidance providing supervisory expectations on how financial institutions should handle consumer deposit discrepancies. Interagency guidance states that banks should avoid or reconcile, or resolve discrepancies between the amount they credit to a consumer’s account and how much was actually deposited. The guidance calls on banks to adopt policies that treat consumers fairly when they make deposits and do not violate law. The referenced law is UDAAP (Unfair or Deceptive Acts or Abusive Practices), and that requirement has raised the compliance bar since being expanded by the Dodd-Frank Act. Let our experienced, former, Federal Compliance Examiners review your product and service offering practices to make sure that UDAAP does not come into play in a negative manner.