Compliance Blog

Dec 09, 2010
Categories: Consumer Lending

This and That...

Posted by Anthony Demangone

Here are some items of interest.

  • You may have caught on to the fact that I enjoy reading the works of Felix Salmon.  In this post, Mr. Salmon dissects a disclosure he received from his bank.  As you'll read, the disclosure is nearly impossible to understand.  The post is a nice reminder of this fact: we write or disclose words to communicate. What are you trying to say?  Once you know that, say it as clearly as possible.  There are times when we must use precise words or "legal terms of art."  Outside of those times, though, writing or disclosures should be clear and easy to understand.  Don't use 50-cent words when a nickel buys you exactly what you need. Don't force readers to choose between confusion and reaching for a dictionary.  And you should hire a monkey to slap you whenever you use any of the following terms in a document meant for general consumption: heretofore, whereas, or any Latin phrase.  
  • The Fed has updated its Consumer Compliance Handbook.  Here's how I use these handbooks.  Someone may ask you for an overview of Regulation E.  You know all about Regulation E, but you are swamped.  Why not refer them to the Reg E portion of the handbook? Or use the handbook when building a training program to make sure you don't forget something important.  In an age of increasing work demands, always lean on trusted resources whenever possible. 
  • I'll say this, Elizabeth Warren certainly isn't shy when speaking about her plans for the CFPB. In her cross-hairs? Credit cards and mortgages.   (Kiplinger.com) (Hat tip to Mr. Harrigan.)