ABA Bank Compliance - March/April 2017

• 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 be occurring.