Account-Information Access

Using its advisory process to issue guidance that may lead to enforcement actions, the Bureau has for the first time set standards for the obligations of large banks and credit unions to respond to certain consumer inquiries.  Going forward, virtually all requests specific to a consumer’s deposit or loan account within an IDI or credit union over $10 billion in assets will require a prompt, complete response without additional fees or any other obstacles the Bureau could deem a violation.  No specific standards are set for criteria such as timeliness, making it a matter of subjective CFPB judgment that could lead to uneven enforcement and/or use of information-related penalties in the context of other Bureau actions, including those designed to penalize “repeat offenders.”