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Checking Account Disclosures
CBA believes that making banking functions transparent and upfront to consumers is a vital part of the bank-consumer partnership. We remain concerned about legislation or regulation that may go too far and actually cause consumers more financial harm than good. For example, a prohibition on overdraft protection programs, or rules so onerous that they act as de facto restrictions, could hurt consumers more than benefit them. CBA stresses improved information to consumers and better financial education.
- March 1, 2018 - 2:00PMPastFebruary 24, 2018Is alternative credit data the missing link between underestimated consumers and access to credit? Consumers with poor traditional credit scores can often be misclassified as marginal or subprime, and many consumers who lack an established credit history are considered ‘unscorable’. By providing the additional insight needed to more predictively evaluate the risk of these consumers, alternative...October 31, 2017 - 1:00PMPastOctober 17, 2017 - 2:00PMPastJune 8, 2017On Thursday, June 8, 2017, CBA and ABA submitted a comment letter in response to the Department of Education’s (DOE) “Request for Information Regarding Disclosures for Student Financial Accounts.” In May the DOE issued the RFI requesting comment on using a model disclosure very similar to that of the recently enacted model short-form disclosure for prepaid cards. In our comment, we strongly...April 19, 2017Many industries, such as financial services, are looking to develop ways to leverage mobile capabilities. The goal is to use mobile to attract new customers, but also to engage and cement relationships with current customers. The challenge lies in the execution. To be effective, you’ll need to determine how to develop innovative ways to leverage the technology and your data and turn that into an...December 19, 2016On Monday, December 19, 2016, in its second action against the company, the CFPB announced a consent order reached with Military Credit Services, LLC (MCS) resulting from alleged improper contractual disclosures. Specifically, the Bureau alleged violations of the Electronic Fund Transfer Act and Truth in Lending Act, and their implementing regulations – E and Z respectively. According to the...November 9, 2016 - 2:00PMPastJune 21, 2016 - 2:00PMPastThe checking account remains the lifeblood of consumer banking. No bank or credit union can survive without a robust acquisition program. But the market is changing - and not in obvious ways.March 30, 2016This week, the CFPB indicated credit card issuers will receive an email with updated instructions regarding submission requirements for sending credit card agreements to the Bureau per The Truth in Lending Act and Regulation Z. The one-year reprieve from this requirement now has expired. The CFPB has attempted to alleviate the submission burden by allowing issuers to send webpage links in lieu of...