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CFPB States Reopening Closed Accounts May Violate The CFPA

On May 10, 2023, the Consumer Financial Protection Bureau (“CFPB”) issued Consumer Financial Protection Circular 2023-02 (“CFPC  2023-02” or the “Circular”). In CFPC 2023-02, the CFPB considers the following question: After consumers have closed deposit accounts, if a financial institution unilaterally reopens those accounts to process a debit (i.e., withdrawal, ACH transaction, check) or deposit, […]

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FDIC and OCC Issue Additional Overdraft Guidance

On April 26, 2023, both the Federal Deposit Insurance Corporation (“FDIC”)[1] and the Office of the Comptroller of the Currency (“OCC”)[2] issued additional guidance regarding overdraft and non-sufficient funds (“NSF”) transactions and fees. Both publications included a discussion of unfair, deceptive, or abusive acts and practices (“UDAAP”)[3] risks associated with “Authorize Positive, Settle Negative” (“APSN”) […]

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Back in the Saddle Again - Townstone Financial

In October 2021 the U.S. Department of Justice (DOJ) announced the launch of a new redlining enforcement initiative.  Since that time, government agencies such as the Consumer Financial Protection Bureau (CFPB), the DOJ, the Federal Housing Finance Agency (FHFA), and the Federal Trade Commission (FTC) have all ramped up enforcement and supervisory activities focused on […]

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Employee Spotlight: John Murphy, Principal Software Engineer

Seven Question with Principal Software Engineer, John Murphy! Meet John Murphy! He’s our Principal Software Engineer at RiskExec and this April, we celebrated his 5th anniversary with our team! Describe what you do at Asurity in 3 words or less.JM: I build RiskExec. How did you discover your passion for software programming/engineering?JM: I have always […]

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