Every once in awhile, you find a rant worthy of notice. Compliance expert Nancy Derr-Castiglione's recent "end-of-my-rope" sceeed in the ABA Banking Journal qualifies.
Nancy's bottom line: consumer compliance disclosures currently required by federal and state law in connection with most loan transactions are so dense and so voluminous that they amount to an "unfair and deceptive trade practice" under Section 5 of the Federal Trade Commission Act. Obviously, Nancy's got her tongue planted in her cheek, yet not so far in that you don't take her seriously.
She has a few suggestions:
- Put a moratorium on any new disclosures
- Eliminate unnecessary disclosures
- Shorten or reduce existing disclosures
Here's one she didn't suggest but that others have suggested for quite some time:
- Keep the %$#*(& lawyers out of the room.