Pub. 7 2019 Issue 3

ISSUE 3. 2019 9 Victoria E. Stephen Deputy General Counsel Victoria E. Stephen, CRCM, serves as Associ- ate General Counsel for Compliance Alliance and was recently appointed as the supervising attorney of Hotline. While receiving her Bachelor of Business Administration in Banking Finance from The University of Texas McCombs School of Business, Victoria worked in both deposit and lending services. She con- tinued her interest in financial services at the University of Texas School of Law by focusing on secured transactions, taxation, contracts, and corporate governance. Victoria has since worked in corporate tax law, mergers and acquisitions, and performed legal research on a range of regulatory issues. Since joining the Compliance Alliance team in 2015, Victoria has written many articles for a variety of publications, and spoken at a number of compliance schools and conferences. Victoria heads our team of hotline attorneys who assist members with the spectrum of regulatory com- pliance questions on a daily basis, and serves as Editor of Compliance Alliance's monthly Access Magazine. Another issue cropped up with accounts that were paid-in-full or settled-in- full. Certain institutions had a practice of deleting the identification number when an account was paid in full, and this practice changed the search key that the furnishers used for matching when making account updates. As a result, the CFPB found that almost two thousand accounts were not updated to reflect the correct paid-in-full or settled-in-full status. Finally, the Bureau found that when some institutions received consumer disputes, they continued furnishing information about the disputed accounts for several months without providing the CRA with notice that the information was disputed, in clear violation of the FCRA. In response to these findings, the CFPB required them to set up enhanced monitoring activities, as well as poli- cies and procedures on compliance with furnisher-specific requirements of the FCRA, in addition to providing evidence of corrective actions. MORTGAGE LOAN ORIGINATION The focus of this section was on the inac- curate disclosure of annual percentage rates and total annual loan costs in re- verse mortgage transactions. While most of our members do not originate reverse mortgages, this is still a sobering remind- er of how pervasive a failure to properly calculate the APR can be, and the very high cost of consumer restitution. So this covers the key takeaways that are most likely to affect our community bank members, but if you’re interested in reviewing the review in its entirety, you can access it at: https://files.consumerfinance.gov/f/ documents/cfpb_supervisory-high- lights_issue-19_092019.pdf n