How refreshing to get a proposal from the CFPB that totals less than 100 pages. On August 15, 2012 the Consumer Financial Protection Bureau (CFPB) published a 58-page release that contains proposed rules to implement a Dodd-Frank Act requirement that amends appraisal rules to help inform mortgage applicants on how a creditor determines a property’s value prior to closing on the mortgage. It will also make it easier for loan applicants to determine if a loan […]
Tag: ECOA
STATUS OF OTHER PENDING RULES
We received a lot of positive feedback about yesterday’s blog entry on the status of changes to Regulation Z. Several of you inquired about the status of other pending rules, particularly those involving Regulations B and C. Well here you go… Regulation B – The Dodd-Frank Act amended the Equal Credit Opportunity Act (ECOA) to require financial institutions to report information concerning credit applications made by women- or minority-owned businesses and small businesses. The amendments […]
DISCRIMINATION AND THE LAZY BANKER SYNDROME
In a recent case the FDIC claimed a bank violated ECOA and Regulation B by engaging in a pattern or practice of denying applications for a credit card based on an initial match of applicant names to the Office of Foreign Asset Control’s list of Specially Designated Nationals (“SDNs”) without further verification that the applicants were in fact SDNs, which resulted in a disparate impact upon Hispanic applicants. The bank agreed to pay a civil […]
CFPB BULLETIN 2012-04 –FAIR LENDING
On April 18, 2012 the Consumer Financial Protection Bureau issued CFPB Bulletin 2012-04 that explains the agency’s position on compliance with the Equal Credit Opportunity Act and Regulation B. The bulletin does not offer any new insights into Fair Lending issues, but the CFPB certainly makes it clear that the agency is focusing on fair lending issues not only in mortgage lending, but also in credit cards, student loans and auto loans. A copy of […]
THE CFPB INHERITS REGULATION B
The Equal Credit Opportunity Act (ECOA) makes it unlawful for creditors to discriminate in any aspect of a credit transaction on the basis of sex, race, color, religion, national origin, marital status, or age (provided the applicant has the capacity to contract), because all or part of an applicant’s income derives from public assistance, or because an applicant has in good faith exercised any right under the Consumer Credit Protection Act. Historically, ECOA has been […]