Deposit Accounts

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The FDIC has issued a final rule that establishes a new framework for analyzing whether deposits made through deposit arrangements qualify as “brokered deposits” and amends the methodology for calculating the interest rate restrictions that apply to less than well capitalized insured depository institutions (IDIs).  The final rule, which includes material differences from the FDIC’s…

We review the following findings and discuss their compliance implications: FCRA violations based on obtaining credit reports without a permissible purpose, incorrectly reporting the date of first delinquency, failing to conduct reasonable dispute investigations; Reg. E violations based on waivers of consumers’ dispute rights, use of incorrect date to determine timeliness of error notices, providing…

The CFPB has released the Summer 2020 edition of its Supervisory Highlights.  The report discusses the Bureau’s examinations in the areas of consumer reporting, debt collection, deposits, fair lending, mortgage servicing, and payday lending that were completed between September 2019 and December 2019.

Key findings are described below.

Consumer reporting.  CFPB examiners found:…

The CFPB recently announced that it has issued a Compliance Assistance Statement of Terms Template (“CAST Template”) through its Compliance Assistance Sandbox Policy (“CAS Policy”) after receiving an application from Build Commonwealth, Inc. (“Commonwealth”).

The Commonwealth CAST Template can be used by employers as the basis for an application to the CFPB to obtain…

We look at the impact of federal and state law including relevant CARES Act provisions, state garnishment directives, and federal preemption, identify issues banks should consider in handling garnishments or exercising setoff rights, and offer suggestions for mitigation measures banks can take as they decide how to address the challenges in this area.

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The CFPB issued two sets of FAQs that discuss assistance that financial services providers can offer consumers during the COVID-19 pandemic.

One set of FAQs is directed at providers of checking, savings, or prepaid accounts.  The FAQs deal with an account provider’s ability to change account terms and the ways account providers can provide immediate…

Effective April 24, 2020, the Federal Reserve amended Regulation D to remove the six-per-month limit on transfers or withdrawals from the definition of a “savings deposit.”  The amendment is set forth in an interim final rule published in the Federal Register on April 28.  Comments on the interim final rule must be filed by June…