OCC Counsel Julie Williams Speaks Out On Consumer Disclosures

A couple of quotes from her speech text illustrate Williams' concerns with the industry's current consumer disclosure practices:

• Shouldn’t we all be concerned if I’m getting more meaningful, comprehensible disclosure when I buy a bag of potato chips than when I commit my current and future financial resources, my hopes and my dreams, taking out a mortgage to buy a home?

• How could we say that a bank is operating safely and soundly, regardless of how profitable it may be, if its revenues and capital were the product of deception, or discrimination, or other activities that are illegal or illicit?

• One thing I have learned in focusing more intently on this area over the past few years – lawyers and technicians – however well intentioned – should never be put in charge of drafting consumer disclosures.