Fact Pattern

You are still both compliance and risk officer for Fargo Non-Compliant National Bank, a $50 billion asset national bank headquartered in Orlando, Florida. One of the loans made by the bank was a closed-end loan in the amount of $80,000.00 for 15 years secured by a dwelling. The bank customer has complained that the requested payment amount on their payment booklet reflects an additional $20 in finance chargesthat was not reflected on their disclosures. Your finance department has determined that indeed the requested payment amount is in excess of the disclosed finance charge.

Assignment

• A memorandum identifying any major potential violations of TILA and/or RESPA so that the CEO can determine what course of action to take on this loan.
• The CEO asked you to find any other examples of other financial institutions where this violation may have occurred. Review the Consumer Financial Protection Bureau Consumer Complaint Database (filter by mortgages) available at https://www.consumerfinance.gov/data-research/consumer-complaints/Links to an external site.
• For the examples you find, discuss whether you can determine how the financial institution resolved the complaint
• Finally, discuss any policy changes that bank should make to prevent further non-compliance.