FDIC Releases Consumer Compliance Supervisory Highlights

The FDIC released its latest Consumer Compliance Supervisory Highlights. This edition includes supervisory observations related to consumer protection laws, examples of practices that may be useful in mitigating risks, regulatory developments, and consumer compliance resources. The issue includes good information on RESPA referral arrangements, trigger leads under the FCRA, and applying excess interest payments on SCRA covered loans. It is a recommended read for all institutions. 

CFPB Publishes Policy Statement on Abusive Acts & Practices

The CFPB published a Policy Statement on Abusive Acts or Practices which offers a framework that may help institutions identify practices that may fall under the scope of “abusive." The Statement discusses the prohibitions that trigger an abusive act: materially interfering with consumers’ understanding of terms and conditions, taking unreasonable advantage, lack of understanding, inability of consumers to protect their interest, and reasonable reliance.