Maybe coincidentally, in coordinated actions three business times after launch of the proposed Supervisory Guidance, the OCC and also the FDIC 
imposed civil money charges totaling ten dollars million and restitution instructions aggregating $3.9 million on RBS people, N.A. and a joint venture partner for violations associated with UDAP provisions of Section 5 regarding the FTC Act associated with overdraft re re re payment and checking rewards programs, and poor handling of prevent payment requests regarding pre authorized recurring electronic investment transfers.
These actions implemented other customer security enforcement purchases early in the day in 2013 because of the OCC and also the FDIC.
Taken alongside the proposed Supervisory Guidance, the OCC and FDIC sales suggest a reinvigorated mindset to customer security things during the Agencies. Continue reading The Board’s Statement reflects a method distinctive from compared to the Agencies to your DAP problem.