Archive

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 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 […]

On November 29th the Consumer Financial Protection Bureau (CFPB) published a notice and request for information about streamlining the inherited regulations. The “inherited regulations” include 14 existing consumer regulations that the CFPB inherited from other regulatory agencies on July 21, 2011, including, among others, Regulation Z (Truth in Lending) and Regulation X (RESPA). The inherited regulations are published in Chapter X of Title 12 of the Code of Federal Regulations. Following is the schedule of […]

On July 6 the Federal Reserve Board approved final rules to implement the credit score disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act. If a credit score is used in setting material terms of credit or in taking adverse action, the statute requires creditors to disclose credit scores and related information to consumers in notices under the Fair Credit Reporting Act (FCRA). The final rules amend: Regulation V (Fair Credit Reporting) […]