Tag: consumer protection

4 articles tagged “consumer protection”

Reg DD Truth in Savings (12 CFR 1030) With AI Deposit-Product Recommendations: The APY Formula the Rule Actually Prescribes, the Change-in-Terms Notice, and Where an AI Cross-Sell Crosses Into Deception

Reg DD is the deposit-side companion to Reg Z: it prescribes a single APY formula, requires specific account-opening and periodic-statement disclosures, and imposes a 30-day advance-notice regime for adverse changes in terms. The AI cross-sell that suggests a higher-yield product, the retention offer that promises a rate, and the chatbot that answers 'what's my rate?' are all Reg DD surfaces. Where the disclosures actually have to appear, and where an AI conversation crosses the line into a UDAAP problem.

Jul 31, 202613 min read

Reg E Subpart B (1073) Remittance Transfers With AI Agents: The 30-Minute Cancellation Window, the Pre-Payment Disclosure, and the Error-Resolution Timeline the Bank Cannot Miss

The remittance transfer rule at Reg E Subpart B is where a consumer's international transfer becomes a specific federal-compliance surface with specific disclosure content, a specific cancellation window, and a specific error-resolution timeline the bank has to run correctly for every consumer transfer. The rule's mechanics have specific timing that maps to specific system-design constraints the AI agent operates against, and the specific compliance points are the specific engineering discipline the bank's remittance program has to enforce.

Jul 24, 202611 min read

UDAAP for AI Agents in Consumer Finance: What "Materially Interferes" Actually Looks Like in a Chat Transcript, and the Consumer-Experience Test the CFPB Applies

UDAAP is the rule every consumer-facing AI system in banking is ultimately measured against, and it is also the rule with the least specific text. The CFPB's Circular 2023-03 on chatbots, the 2022 exam manual update that was later rescinded, and the enforcement pattern under 12 USC 5531 and 5536 set the practical standard the agent has to clear. What we score against on every conversation, and why the consumer-experience test is the one that matters more than the internal QA test.

Jul 10, 202613 min read

AI Chatbots in Consumer Finance: What the CFPB Spotlight Named and Who Enforces It in 2026

The CFPB's 2023 chatbot spotlight named real failure modes, and they did not disappear when the Bureau pulled back. The doom loop, missed federal rights, and UDAAP exposure, who enforces them now, and the controls that hold up.

May 24, 20266 min read

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