Legal Blog

Compensation and Compliance Matters: Financial Institutions Will Pay If They Fail to Supervise Third Parties

On Sept. 25, the Consumer Financial Protection Bureau, in conjunction with the Office of the Comptroller of the Currency, issued a consent order against U.S. Bank for illegal billing practices which specifically implicated a lack of third party service provider oversight and management by U.S. Bank. U.S. Bank contracted with a TPSP to provide identity protection services and credit monitoring services. As per the CFPB consent order, consumers were billed for services they did not receive; were charged unfairly for interest and fees pertaining to customers’ credit limits and interest charges for services that they never received; and under the mis-impression that the above-listed credit services were being performed. Of note, there is no indication of intent on the part of U.S. Bank to deceive, defraud, overcharge and/or otherwise harm its customers.

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If you have any questions please contact Ari Karen at:

Bank Manager  | 240.507.1740

Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide.

Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.

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