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In a recent consent order with a national bank, the CFPB found that the bank committed UDAAP violations in its process for handling garnishment orders and by including certain waiver language in its deposit account agreements. We discuss the specific aspects of the bank’s process that the CFPB found to be improper and what banks should consider when reviewing their own garnishment procedures in light of the consent order. We also look at what the consent order means for how banks can address liability concerns arising out of the handling of garnishment orders in deposit account agreements.
Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation, joined by Mike Gordon, a partner in the firm’s Consumer Financial Services Group, and Jessica Simon, Of Counsel in the firm’s Bankruptcy and Restructuring Group.
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