What items should you be on the lookout for within your institution based on recent guidance that has come out from the CFPB?
One item that should be of particular attention is production incentives. If you are offering this type of incentive, the impact that this may have to incentivize consumer harm to your consumer, as well as pose both financial, and regulatory risk to your institution as well as reputation risk, consumer harm and the potential loss of customers. This video reviews the CFPB compliance bulletin 2016-03 and concerns over incentive programs posing risk to consumers when not carefully and properly implemented and monitored; and what the CMS CFPB’s expectations are.
Agenda
Faculty
Susan Chylik
McGlinchey Stafford PLLC
- Member in the Cleveland office of McGlinchey Stafford PLLC
- Represents banks, finance companies, mortgage companies and consumer lenders advising them on regulatory compliance for consumer loan documentation, e-commerce, underwriting, and servicing and collections practices
- Assists companies in responding to state and federal examinations, including Civil Investigative Demands issued by the CFPB
- Presents annually at the Wolters Kluwer and McGlinchey Stafford Consumer Financial Services Conference on servicing issues affecting the financial services industry
- American Bar Association Consumer Financial Services Committee, member and Young Lawyer Liaison to the Electronic Financial Services Subcommittee; Ohio State Bar Association member
- J.D. degree, The Ohio State University Moritz College of Law
- Can be contacted at 216-378-9913 or [email protected]
Jeffrey P. Barringer
McGlinchey Stafford PLLC
- Member in the Albany office of McGlinchey Stafford PLLC
- Practice emphasizes all aspects of state and federal consumer financial services regulatory compliance for creditors/servicers operating in several states or nationally
- Regularly assists creditors/servicers respond to regulatory inquiries and examination issues
- Regularly presents on regulatory compliance issues relating to mortgage origination
- American Association of Residential Mortgage Regulators, Industry Advisory Council; New York Mortgage Bankers Associations, Board member and Legislative Committee member; American Bar Association; member, Consumer Financial Services Committee
- J.D. degree, summa cum laude, Albany Law School
- Can be contacted at 518-874-3428 or [email protected]
Robert Savoie
McGlinchey Stafford PLLC
- Senior associate in the New Orleans office of McGlinchey Stafford PLLC
- Practice regularly involves assisting state and national banks, mortgage lenders, motor vehicle sales finance companies, and small dollar lenders with substantive consumer financial services compliance and with CFPB and other governmental agency examinations and civil investigative demands
- Conducted presentations on a wide variety of topics, ranging from debt collection issues and mortgage servicing rules for American Bar Association meetings and webinars to Servicemembers’ Civil Relief Act compliance in the context of Department of Justice examinations
- Published articles on subjects ranging from mortgage servicing to debit card interchange fees to mortgage foreclosure compliance
- J.D. degree, Notre Dame Law School, 2010
- American Bar Association, member, Consumer Financial Services Committee, vice-chair of the Young Lawyers’ Subcommittee
- Can be contacted at [email protected] or 504-596-2797
Brian Fink
McGlinchey Stafford PLLC
- Of Counsel in the D.C. office of McGlinchey Stafford PLLC
- Advises depository and nondepository financial institutions on aspects of compliance, government investigations, and regulatory issues and has extensive high-level experience with the CFPB and Banking Regulators
- Prior experience includes serving as supervisory analyst, attorney advisor, and senior analyst within the CFPB's Office of Supervision Policy and focusing on CFPB's payday, deposit and over-draft, mortgage origination, and automobile origination examination programs. Resolved complex examination issues, with particular emphasis on issues relating to the Truth in Lending Act, Real Estate Settlement Procedures Act, Truth in Savings Act, Electronic Funds Transfer Act, and the determination of unfair, deceptive, and abusive acts and practices (UDAAP)
- J.D. degree, Hamline University,1999; M.B.A. degree, University of St. Thomas, 2002
- Can be contacted at [email protected] or 202-802-9955
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