The CFPB ordered community banks to pay more than $3 billion to consumers last year, and most of those actions stemmed from flawed disclosures, says Jenna Burke, ICBA's executive vice president and general counsel. Regulators have been intensely scrutinizing banks' disclosures over concerns about UDAAP violations, she explains.
Many problems arise when products, services, and websites change but disclosures don't, particularly when third parties are involved. Burke advises banks to ensure their disclosures are accurate and consistent with the services they offer, to consider them from the consumer's perspective, and to use a "four-P framework" to guide disclosure reviews, among other suggestions.
Does your institution frequently review its disclosures and update them after product or website changes? Is this something you've discussed with regulators? Any advice for the broader group?
------------------------------
Rob Blackwell
Chief Content Officer and Head of External Affairs
IntraFi
Arlington, VA
------------------------------