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:
- Review the basics of the change in terms provisions of the consumer regulations for consumer loan and deposit accounts
- Include a discussion of the change in terms requirements for consumer credit card accounts, including creditors’ responsibilities if the consumer rejects the change in terms
- Cover the change provisions that apply to early disclosures for a consumer closed-end mortgage loan, otherwise known as a “changed circumstance”
- Discuss the impact of changing terms on business accounts, including laws and regulations that impact both consumer and business products such as flood insurance regulations and Regulation CC
- Discuss the overall impact of the Unfair, Deceptive and Abusive Acts or Practices (UDAAP) law on compliance risks for managing changes in terms decisions
Who Should Attend: Compliance officers, marketing staff, product managers, auditors