Archive

PROPOSED CHANGES TO REGULATIONS B AND C

The CFPB has been busy with proposed changes in recent weeks.  Two proposed changes released by the CFPB will impact most financial institutions to some degree.  The CFPB released proposed changes to Regulation B on March 24, 2017.  The proposal is designed to permit creditors additional flexibility in complying with Regulation B – ECOA, in order to facilitate compliance with Regulation C – HMDA.  This proposal was not unexpected.  In addition, the CFPB released changes […]

PROPOSED CHANGES TO REGULATION B

The CFPB released proposed changes to Regulation B on Friday, March 24th.  The proposal, a mere 56 pages, is designed to permit creditors additional flexibility in complying with Regulation B, in order to facilitate compliance with Regulation C – HMDA.  This proposal was not unexpected. In October 2015, the CFPB issued final rules to implement changes to Regulation C that allow an applicant to self-identify using disaggregated ethnic and racial categories.  These rules are generally […]

CFPB SEEKS INFORMATION ON ALTERNATIVES TO TRADITIONAL CREDIT REPORTS

On February 16, 2017 the Consumer Financial Protection Bureau (CFPB) issued a request for information (RFI) on the potential use of alternative data and modeling techniques in the credit process. The goal of the CFPB’s inquiry is to explore options that will expand access to credit for consumers who are credit invisible or who lack enough credit history to obtain a credit score. In May 2015 the CFPB released “Data Point: Credit Invisibles” which was […]

REGULATION B AND THE NEW UNIFORM RESIDENTIAL LOAN APPLICATION

On September 23 the Consumer Financial Protection Bureau (CFPB) published an Official Approval concerning the new Uniform Residential Loan Application and the collection of expanded Home Mortgage Disclosure Act information about ethnicity and race in 2017. The official approval was issued on September 23, 2016. Entities may rely on the official approval beginning January 1, 2017. The official approval is issued separately from, and without amending, the official interpretations to Regulation B contained in Supplement […]

UNIQUE AND DISGUSTING FAIR LENDING CASE

On June 29th, the Consumer Financial Protection Bureau (CFPB) and the Department of Justice (DOJ) announced a joint action against BancorpSouth Bank for discriminatory mortgage lending practices that harmed African Americans and other minorities.  The complaint filed by the CFPB and DOJ alleges that BancorpSouth engaged in numerous discriminatory practices, including: Illegally redlining in Memphis; Denying certain African Americans mortgage loans more often than similarly situated non-Hispanic white applicants; Charging African-American customers for certain mortgage […]