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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Credit Reporting: Need to do it right the first time every time

As with so many things in life, credit reporting is something that if done must be done precisely. Errors impact not only the credit reporting system and business decision making but it also impacts real people. A recent consent order pointed out how even innocent errors can harm individuals and violate the law. The use…

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