In this video our speaker, Richard J. Andreano, reviews how the manual defines unfair, deceptive, and abusive acts and practices, and provides examples of each. He also discusses the role of complaints in the manual. The manual provides that consumer complaints play a key role in the detection of unfair, deceptive or abusive practices. Consumer complaints can indicate weaknesses in elements of the institution’s compliance management system, such as training, internal controls or monitoring. Because the perspective of a reasonable consumer is one of the tests for evaluating whether a representation, omission, act, or practice is potentially deceptive, consumer complaints alleging misrepresentations or misunderstanding may provide a window into the perspective of the reasonable consumer.
Richard J. Andreano is a Partner and practice leader of the mortgage banking group at Ballard Spahr LLP. He is a Fellow with the American College of Consumer Financial Services Lawyers. Mr. Andreano counsel clients on residential mortgage regulatory matters, including ability to repay, TILA/RESPA integrated disclosure (TRID) rule, CFPB supervision and examination, UDAAP and other Dodd-Frank matters.
Agenda
Faculty
Richard J. Andreano
Ballard Spahr LLP
- Partner at Ballard Spahr LLP
- Practice leader, Mortgage Banking Group, Ballard Spahr LLP
- Fellow, American College of Consumer Financial Services Lawyers
- Chambers USA: America's Leading Lawyers for business, banking and finance: financial services regulation: consumer finance (compliance), national ranking, 2014 to 2017
- Wrote MBA Compliance Essentials Loan Originator Compensation Resource Guide™, published by the Mortgage Bankers Association
- Co-wrote, MBA Compliance Essentials TILA/RESPA Integrated Disclosure TRID Rule Resource Guide™, published by the Mortgage Bankers Association
- Editor-in-chief, Mortgage Finance Regulation Answer Book 2011-2012, published by the Practising Law Institute; author of chapters on the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Home Mortgage Disclosure Act, and the Real Estate Settlement Procedures Act; and co-author of the Equal Credit Opportunity Act and Truth in Lending Act chapters
- Counsels clients on residential mortgage regulatory matters, including ability to repay, TILA/RESPA integrated disclosure (TRID) rule, CFPB and other regulator supervision and examination, UDAAP and other Dodd-Frank matters
- Frequent speaker and author on mortgage industry issues
- Can be contacted at 202-661-2271 or [email protected]
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