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CFPB provides guidance on FI responsibilities during coronavirus
The CFPB yesterday released a statement and two FAQ documents to offer guidance on financial institutions' responsibilities when assisting customers during the coronavirus pandemic.
In the statement, the bureau outlined supervisory guidance on Regulation Z billing error resolution timeframes. It noted that many financial institutions may be facing operational disruptions, making it difficult for creditors to accurately and timely resolve customers' billing error notices resulting in both consumer and merchant damage.
In light of these considerations, the bureau said it will take a flexible supervisory and enforcement approach during the pandemic regarding the timeframe within which creditors complete their investigations of consumers’ billing error notices.
Specifically, the CFPB does not intend to cite a violation in an examination or bring an enforcement action against a creditor that “takes longer than required by the regulation to resolve a billing error notice, so long as the creditor has made good faith efforts to obtain the necessary information and make a determination as quickly as possible, and complies with all other requirements pending resolution of the error.”
To provide further guidance on this topic, the CFPB also released a set of FAQs on payments and deposits rules as they relate to the coronavirus pandemic and a set of FAQs on open-end, non-home secured credit.
Of note, the FAQs on payments and deposits reminded financial institutions that Regulations E and DD allow for a change in account terms without advance notice if the change is clearly favorable to the borrower. The FAQs also addressed the recent change to Reg D, saying that financial institutions can eliminate transfer fees on savings accounts without providing advance notice.
NAFCU recently discussed with the CFPB the Federal Reserve's recent interim final rule that eliminates the six-per-month transaction limit between savings and checking accounts under Regulation D and credit unions' concerns regarding how this change could impact Regulation CC compliance.
Visit NAFCU's Compliance Blog to get insights into several of these topics and other compliance issues.