• Don’t create a false sense of urgency
for customers by telling them they
must call back by the end of the
business day or they would be
turned down, if that is not the case.
We’ve seen this before, and marketing must reflect actual practices.
Don’t use this tactic to pressure
potential and existing customers if
the offer will still be accepted beyond that day. Don’t affiliate your
company with the U.S. government
(for example, stating “you qualify
for a reverse mortgage from the U.S.
Housing Department”). We all know
we’re special; Maybe just not “U.S.
Government” special. Be truthful
about all affiliations.
■ ■ ■ The Bureau took action against four
pawn brokers. Each was cited for deception for the simple reason that they disclosed incorrect APRs on most of their
contracts.. This may be a sign of coming
attractions by more closely aligning
UDAAP and Reg Z.
And, that’s what’s new with UDAAP. ■
ABOUT THE AUTHOR
MEG SCZYRBA, J.D., CRCM,
has been involved in the
compliance industry for over
20 years and currently chairs
the Boards of the ABA
Compliance School and ABA Bank
Compliance magazine. She is the Fair and
Responsible Banking Risk Program Manager
at a large bank and was honored as ABA’s
2011 Distinguished Service Award recipient.
Any opinions expressed in this article are the
author’s own and do not reflect the views of
her employer or the ABA.
This is a new foray for
bankers, but deposit
products and overdraft
protection in particular
should be carefully
scrutinized for any
indicators that unfair or
deceptive activity may