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Compliance Blog highlights CFPB's one-click away rule, supervisory activities
NAFCU Regulatory Compliance Counsel David Park breaks down the CFPB's one-click away rule, which was highlighted in the bureau's 19th edition of its supervisory activities highlights, in a new post on the Compliance Blog. The report – released by the bureau last month – provides insights into auto loan origination, credit card account management, debt collection, furnishing, and mortgage origination.
The report also provides a summary of the bureau's recent rules and guidance – including the small entity compliance guide, memorandum of understanding with the FTC, and amendments to the annual privacy notice requirement under the Gramm-Leach-Bliley Act.
In the blog, Park details one-click away rule requirement violations, which include:
- using a hyperlink that was not labeled to refer to the triggered disclosures and then requiring the consumer to go through the entire credit card application before providing the triggered disclosures; and
- using a series of hyperlinks and not permitting the consumer to view the triggered disclosures until completing a credit card application.
Park also directs those who wish to obtain more guidance on credit union advertising rules to the association's new member-only NAFCU Credit Union Compliance Advertising Guide.
For more on the one-click away rule and highlights from the CFPB's report, read Park's blog. Those interested can sign up to receive new NAFCU Compliance Blog posts in their inbox every Monday, Wednesday and Friday.