Lesley Smith DeRamus

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Lesley DeRamus has over 25 years of experience advising financial institutions on consumer protection laws and regulations impacting their operations. She regularly advises financial institutions on regulatory issues and develops forms, procedures and strategies for compliance. Also, she frequently advises clients on issues related to agency examinations and litigation matters. Lesley has advised institutions on both deposit and credit regulatory issues.  View articles by Lesley

Latest Articles

Security researchers and cybersecurity experts recently discovered a weakness in Fiserv’s web platform, which may have exposed the personal and financial details of customers across hundreds of internet banking sites. The flaw involved a messaging platform used by Fiserv to send account alerts to customers of Fiserv-affiliated banks. These alerts can be set up to notify the customer of certain events, such as when a balance passes a threshold. Someone noticed that the alert was provided in…
The Consumer Financial Protection Bureau (CFPB) issued its final rule on payday, vehicle title, and certain high-cost installment loans. The new rule is effective in 2019 and imposes stringent underwriting requirements and payment restrictions on certain covered loans. Be sure to review our previous blog post “CFPB Releases Long Awaited Small Dollar Rule: 5 Things You Need to Know” for additional information. Fortunately, unlike the CFPB’s original proposals, the final rule seems to have very…
The Consumer Financial Protection Bureau (CFPB) released final amendments to its “Know Before You Owe” mortgage disclosure rule, which is also known as the TILA-RESPA Integrated Disclosure rule (TRID), on July 7, 2017. As stated in the accompanying press release issued by the CFPB, the amendments “are intended to formalize guidance in the rule, and provide greater clarity and certainty” and “will facilitate implementation of the Know Before You Owe rule by the mortgage industry.”…
[This post is the first in a series of post which will examine the risks, rewards, innovative uses, and changing legal landscape of social media use by financial services institutions. Future blog posts will examine topics such as: monitoring and managing consumer complaints through social media, disgruntled employee use of social media, and control over content and message. These forthcoming postswill address the risks associated with these issues and provide practical solutions for mitigating those risks.] Many of…
Last week, the CFPB issued its long-awaited final rule amending Regulation E (Electronic Funds Transfer Act) and Regulation Z (Truth in Lending Act) to create regulations for prepaid financial products (Prepaid Rule). The CFPB’s original proposed rule was issued in 2014. The Prepaid Rule is effective on October 1, 2017, although the requirement to submit prepaid account agreements to the CFPB is not effective until October 1, 2018. Financial institutions do not have to…
In previous blog postings, we discussed an informal announcement from the Consumer Financial Protection Bureau (CFPB) of its intent to delay the effective date of the new integrated mortgage disclosure rule under Truth In Lending Act and the Real Estate Settlement Procedures Act (commonly referred to as the TILA-RESPA Integrated Disclosure rule or TRID rule) and a proposed amendment released by the CFPB to delay the effective date of the TRID rule. The TRID…