Change in Terms – Regulatory Issues for Deposit and Loan Accounts - 2021
Recorded on March 8, 2021 - 2 hours
Have you completed this webinar? Please tell us what you think.
Many of the “traditional” consumer protection laws and regulations include provisions that require a minimum advance notice to the consumer for changes to terms, especially those that negatively impact the consumer. The notice and timing provisions of Regulation E (Electronic Funds Transfer Act), Regulation DD (Truth in Savings), Regulation CC (Expedited Funds Availability Act), and Regulation Z (Truth in Lending Act) are applicable to consumer account changes. Regulation Z rules for changes to accounts varies depending on the type of account and the type of change.
Business customers cannot be completely ignored when it comes to changing the terms of their accounts. For both consumer and business customers, the terms of the contract must be followed and generally supersede any competing regulatory requirement that is less favorable to the customer. Then, there is the overlaying element of UDAAP that applies to all communications and actions taken in relation to the customer. Even if a specific regulatory requirement does not apply to the situation in question or if you are in technical compliance with a regulatory provision, you must consider whether the institution’s practices could be deemed unfair, deceptive or abusive.
In this two-hour webinar we will:
Who Should Attend: Compliance officers, marketing staff, product managers, auditors