The emphasis on Unfair, Deceptive and Abusive Acts or Practices (UDAAP) is increasing. Violations are being cited with increasing frequency. The civil monetary penalties being imposed are substantial. While all of the federal regulatory agencies focus on the issue, the most intense focus seems to come from the Federal Deposit Insurance Corporation (FDIC). While all of the FDIC’s regions appear to be focusing on the issue, the most intense focus appears to be coming from […]
Category: FDIC
DECEPTIVE MARKETING
We have seen a recent string of enforcement actions from the Consumer Financial Protection Bureau involving deceptive marketing practices. There are lessons for all banks to learn from these actions. What the Actions Had in Common The action was taken by the CFPB in coordination with another federal regulator (FDIC in one and OCC in the other). The action involved huge financial institutions. The action resulted in huge penalties. The actions involved deceptive acts in […]
FDIC – VIOLATION CLASSIFICATION SYSTEM
The Federal Deposit Insurance Corporation (FDIC) recently announced (FIL-41-2012) a revision to the classification system for citing violations identified during compliance examinations. The revisions better communicate the severity of violations and help distinguish more serious violations from those more technical in nature. Violations are assigned to one of three classifications based primarily on the impact on the consumer. The three levels are: Level 3/High Severity – includes violations that may result in restitution to consumers […]