Credit card compliance is comprehensive! It isn’t enough to just be up to speed with Reg Z’s open-end rules. Credit card issuers must also be well versed in:
Reg Z’s special credit card provisions, including:
Card issuance
Errors and disputes, including claims for dissatisfaction with goods and services
Prohibition on right of offset
Prompt crediting of refunds
The Credit Card Accountability, Responsibility, and Disclosure Act (Credit CARD Act) provisions, including:
Advance notice for account changes and consumer’s right to reject changes
Periodic statement delivery, disclosure, and content requirements
Payments: minimum amounts, allocation, and cut-offs
Limitations on certain fees, finance charges, and increases in APR
Over-the-limits rule
Ability to Repay requirements
Special rules for “underage” consumers less than 21 years old
Application and solicitation requirements
Differences between credit cards, charge cards, and hybrid prepaid-credit cards
SCRA and MLA relevance on credit card lending
FCRA considerations, including:
Pre-approved offers of credit (prescreening)
Risk Based Pricing Notices or Credit Score Disclosures
Accurate reporting to credit bureaus
Reg B and Fair Lending considerations
Joint owners / Guarantors / Authorized signers
Decisioning tools
Adverse Actions
E-SIGN considerations
Community Reinvestment Act considerations
1071 coverage of business credit cards
UDAP and card rewards programs
Oldies but goodies: BSA / OFAC / CIP / COBO
How do vendors fit in?
Duties and responsibilities – crucial!
Wow! That IS a lot! Get the scoop from a veteran compliance pro (25 years!) who has helped implement compliance credit card programs (from the ground up) in banks of differing sizes. She wrote this program specifically to help the compliance professional who, like her, had no idea where to even begin!
Rebekah F Leonard, CRCM Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to “make clear, explain, throw light upon”, and describes Rebekah’s desire to illuminate the complexities of compliance with passion and fun. She’s created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource.
Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she’s covered nearly all of it – customer service and teller work, loan processing and review, BSA, and security and business continuity. She now oversees CRA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams.
Rebekah has a bachelors’ degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006. She is a BOL Compliance Guru.
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