CRCM: Certified Regulatory Compliance Manager - Consumer Leasing Act Enforcement-15 USC 1667d Section FIRREA Penalties

Consumer Leasing Act Enforcement-15 USC 1667d Section FIRREA Penalties

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Question

Under Consumer Leasing Act Enforcement-15 USC 1667d section FIRREA penalties include:

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A. B. C. D.

AB

Sure, I'd be happy to provide a detailed explanation of the answer options related to FIRREA penalties under the Consumer Leasing Act Enforcement-15 USC 1667d section.

The Consumer Leasing Act (CLA) is a federal law that governs consumer leases, which are leases for personal, family, or household purposes that extend beyond four months and do not involve the lease of real property. The law requires lessors to provide consumers with certain disclosures and protections, including a statement of the total amount due under the lease, a description of any fees or charges, and information about the consumer's rights to early termination of the lease.

Under the CLA, the Federal Reserve Board has the authority to enforce the law and to impose penalties for violations. The Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA) provides additional penalties for certain violations of federal laws and regulations, including the CLA.

Here are detailed explanations of the answer options related to FIRREA penalties:

A. Penalties up to $8,500 per day for violations of laws and regulations This answer option is partially correct. FIRREA does provide for penalties of up to $8,500 per day for violations of laws and regulations, including the CLA. However, this is not the only penalty provision under FIRREA for CLA violations.

B. Penalties up to $37,500 per day if violations or unsafe or unsound practices are engaged in recklessly or are part of a pattern of misconduct that causes more than a minimal loss to the bank or any pecuniary gain to the parties involved This answer option is also partially correct. FIRREA does provide for penalties of up to $37,500 per day for CLA violations if the violations are engaged in recklessly or are part of a pattern of misconduct that causes more than a minimal loss to the bank or any pecuniary gain to the parties involved.

C. Penalties up to $1,375,000 per day against persons who knowingly commit a violation and knowingly or recklessly cause a substantial loss to the bank or a substantial benefit to the party This answer option is also partially correct. FIRREA provides for penalties of up to $1,375,000 per day for CLA violations if a person knowingly commits a violation and knowingly or recklessly causes a substantial loss to the bank or a substantial benefit to the party.

D. Penalties up to $9,500 per day for violations of laws and regulations This answer option is incorrect. While FIRREA does provide for penalties of up to $8,500 per day for violations of laws and regulations, the correct amount is not $9,500 per day.

In summary, the correct answer is either A, B, or C, depending on the circumstances of the CLA violation. If the violation is engaged in recklessly or is part of a pattern of misconduct that causes more than a minimal loss to the bank or any pecuniary gain to the parties involved, the penalty can be up to $37,500 per day. If a person knowingly commits a violation and knowingly or recklessly causes a substantial loss to the bank or a substantial benefit to the party, the penalty can be up to $1,375,000 per day. Finally, if the violation is not reckless or part of a pattern of misconduct and does not cause a substantial loss or benefit, the penalty can be up to $8,500 per day.