During 2009 and 2010, Congress and the Federal Reserve Board made massive changes to the Regulation Z rules that regulate open-end credit. Since that time the Consumer Financial Protection Bureau (CFPB) inherited the regulation and has not made any additional changes to the rules. But questions and problems continue to plague those who offer open-end credit. By following basic procedures these concerns can be eliminated.
The rules for open-end credit require action before, during, and after opening an account. Disclosures are required when opening an account, for each billing cycle and when changes are made. There are very specific rules for resolving errors. Specific guidance is provided for applying payments and for handling credits.
Open-end credit can be secured or unsecured. The credit may be accessed by card, check, or by other means. Disclosure and other rules vary depending on the method of access and the presence and nature of collateral. Disclosures tend to come from more than one source, for example, loan origination software and core accounting systems. Often errors occur because the setup of the two systems lacks consistency.
Errors can result in civil liability, enforcement actions, and reimbursements. Damages are often substantial because errors tend to systematic errors, where the system makes the same error on a consistent basis.
This two-hour program focuses on the basic rules for open-end credit. If a financial institution offers any form of open-end consumer credit staff members need to understand the basic rules that govern the product.
- What is Open-End Credit;
- Coverage and Exemption rules;
- General Disclosure Requirements;
- Account Opening Disclosures;
- Periodic Statements;
- Subsequent Disclosure Requirements;
- Treatment of Credit Balances;
- Special Rules Related to Credit Cards; and
- Billing Error Resolution
Who Should Attend?
The program is designed for management of the loan department, Compliance Officers, lenders, processors, marketing staff, and auditors.
Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 44 years. In 39 years as a trainer over 147,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.
- “Live” Web connection - $265
- 6-month “OnDemand” website link only - $295
- CD-ROM and e-materials only - $345
- Live plus OnDemand website link - $365
- Premier Package: Live, OnDemand link, and CD-ROM plus - $395