USAA Consent Order: The Criticality of Sensible Procedures

Last week, the CFPB issued its first consent order of 2019 and the its first consent order under Director Kathleen L. Kraninger. The Consent Order is with USAA Federal Savings Bank dealing with violations of the Electronic Funds Transfer Act, 15 U.S.C. § 1693, et seq., its implementing regulation, Regulation E, 12 C.F.R. pt. 1005,…

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