31 Hoosier Banker October 2015 About the Author Amber Goodrich is a compliance strategist for the regulatory compliance area of CSI. She has more than 10 years of financial industry experience. Goodrich is a certified regulatory compliance manager and a certified Bank Secrecy Act professional. The author can be reached at 888-494-8449, ext. 17266, email: amber. goodrich@csiweb.com. CSI is an associate member of the Indiana Bankers Association and an IBA Preferred Service Provider in three areas: CSI Secure Connect, CSI Managed Services & Locktite Vault, and CSI WatchDOG Social Compliance. 1 Available at: consumerfinance.gov/guidance/ supervision/manual 2 Available at: consumerfinance.gov/ complaintdatabase example rules regarding proper disclosures—into your loan, BSA, credit card and other policies as an extra precaution. 4. Stay vigilant on mortgage rules. Pay extra attention to the new mortgage rules, which have been a hotbed of UDAAP violations and ensuing enforcement actions. Violations of loan originator compensation rules, in particular, are cited regularly. 5. Make sure “free” means free. Ensure that, when marketing free products like debit or credit cards, they truly are free of any and all fees. Otherwise, the use of this word will be considered deceptive. 6. Monitor customer/consumer complaints. Pay attention to complaints against your institution and others using the CFPB’s public consumer complaint database.2 You can search through the database to gauge which topics are buzzing. Heads-up: When the CFPB witnesses a lot of similar complaints—for example DELAWARE AND NEVADA INVESTMENT SUBSIDIARIES AND HOLDING COMPANIES | CUSTODY PORTFOLIO ACCOUNTING | INVESTMENT MANAGEMENT | CAPTIVE INSURANCE RENOWNED ENTITY MANAGEMENT EXPERIENCE ©2015 Wilmington Trust Corporation and its affiliates. All rights reserved. Affiliates in Arizona, California, Connecticut, Delaware, Maryland, Michigan, Minnesota, Nevada, New Jersey, New York, Pennsylvania, South Carolina, Texas, Vermont, Cayman Islands, Dublin, Frankfurt, London, and Luxembourg. CS7304 MARY ALICE AVERY mavery@wilmingtontrust.com 302.636.6127 MINDY WALSER mwalser@wilmingtontrust.com 702.866.2203 AMY STENGEL astengel@wilmingtontrust.com 302.651.8374 on overdraft protection or debt collection—chances are that CFPB will add those topics to its rulemaking agenda. 7. Evaluate vendor relationships. Financial institutions are increasingly held accountable for the actions of their third-party service providers. Since your institution is responsible not only for its own actions, but also for those of its vendors, be sure to include UDAAP compliance expectations in every thirdparty contract for a solid vendor management program. Although the UDAAP definition will likely remain vague, following these steps will help you steer clear of unknowingly committing consumer violations, as well as their resulting enforcement actions. t
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