Denial of Services After the CFPB/Navy FCU Consent Order
A NorthLegal Webinar Presented November 10, 2016
Duration: Approximately 2:00 hr:min
Cost/Registration | How to Attend a Webinar |
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Handout Materials
After enrolling, click here to obtain the handout materials in PDF. Then contact NorthLegal (623.537.7150) to obtain the password you will need to open those materials.
On October 11, 2016, the Consumer Financial Protection Bureau entered into a "consent order" with Navy FCU that some believe indicates credit unions may not deny services to members who are not current on their debts. Is that really true?
Must a credit union provide ATM access, home banking, automated payments, and all other services to all members? Did the rules change?
There are lessons to be learned from the CFPB consent order—important lessons—and it should not be disregarded. But there are also misunderstandings. In order to learn the right lessons your credit union must know what the consent order said. what it didn't say and how it applies to you.
During this webinar attorney Eric North will talk with participants about "denial of services" laws, court decisions and policies. Topics will include:
| • | Things the CFPB consent order told us that we should already have known. |
| • | What the NCUA has said about providing services to members. |
| • | How courts have viewed denial of services cases. |
| • | Whether a member must have caused the credit union to "suffer a loss" or be in default in order for you to discontinue services. |
| • | Should you include a right to deny services in your loan agreements, deposit account agreements or membership agreements? May you deny services if your agreements don't specifically say you can? If you do want to include denial of services language, what pitfalls should you avoid? |
| • | Whether a member must have caused the credit union to "suffer a loss" or be in default in order for you to discontinue services. |
| • | What bankruptcy law has to say about denying services to members, and why the rules may be different for some credit unions than for others. |
| • | Whether you may use the threat of a loss of services as a way to convince a debtor to pay or a bankrupt member to reaffirm. |
| • | How to communicate your denial of services policy to members—and how saying the wrong thing may cause a court to punish you with sanctions! |
For more information, contact NorthLegal at 623.537.7150. Click here to register using a credit card.
NOTE: This program is intended for employees of credit unions, although much of it will also apply to other consumer lending institutions. Please contact NorthLegal Training and Publications to obtain approval
before registering if you are not an employee of a consumer lending institution.
Cost/Registration
The fee to attend this archived program is $160.00 if paid by credit card or $170.00 if paid by check. For that fee, you or someone from your financial
institution may view this program as often as you like for a period of 180 days. (NOTE: If your financial institution registered for the live program, you already have free access to the archvied version for 180 days! Contact NorthLegal for information.)
How to Attend a Prerecorded Webinar
To attend this NorthLegal Webinar, please do the following:
| • | Register. To register online using a credit card, visit the "Enroll Now" link shown in the box at the top of this page. To register by mail, call NorthLegal at 623.537.7150. |
| • | Check your email. Within moments after you complete the registration process you should receive two emails. One will be a receipt for the transaction and the other will contain a link and detailed instructions explaining how to use that link to attend the program. |
| • | Download the handout materials by clicking the "Handout" link shown above. |
| • | Call NorthLegal to obtain the password to open the handout materials. |
» Archived NorthLegal Webinars
Speaker: Eric North
Eric North, the primary speaker at the programs listed on this site, has represented the interests of credit unions and other financial institutions as an attorney with respect to litigation, compliance, governance, bankruptcy and collections matters since 1984. Eric has appeared in state and federal courts throughout the State of California, and has argued before the Ninth Circuit Court of Appeal.Eric is also a nationally recognized speaker on legal issues relating to consumer lending institutions, and has presented hundreds of programs on behalf of national, state and local leagues and associations from around the country.
Live program scheduling conflict?
No problem! Registration for a NorthLegal webinar automatically entitles you to watch it live AND to watch the archived version as many times as you like for 180 days!
If you or your staff can't make the live program, you still have plenty of time to watch at a time that is more convenient for you!