Live Webinar
Thursday April 21, 2022
10:00 PDT | 11:00 MDT | 12:00 CDT | 1:00 EDT
Must a credit union make all of its services available to all members? May it offer certain services to some members but not to others? Is that illegal “discrimination?” Does the decision have to turn on whether or not the member “caused a loss?” Does it matter which services are being denied?
Several years ago, a large credit union agreed to pay tens of millions of dollars as part of a consent order with the CFPB based in part on the credit union’s denial of services policy. Why? What did they do wrong? Is your credit union making the same mistakes? Was it the CFPB’s position that services may not be denied?
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:
• What various federal laws say about withholding services from members.
• What the NCUA has said about withholding services from members.
• What the issue really was, and what the CFPB said, in the case that made headlines a few years back.
• 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?
• 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!
The rules are not hard, but complying with them does require thought. This program is intended both for collectors and for those in management who develop and approve credit union policies and practices.
For more information, call NorthLegal at 623.537.7150.
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Live Webinar – Denial of credit Union Services – Credit Union Collections – Credit Union Collectors
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