During 2011 HUD settle cases with two lenders involving familial status discrimination. In both cases women on paid maternity leave were told to wait until they returned to their full-time positions credit could be approved. The first case, in August 2011, cost the lender more than $750,000. The first victim received $15,000, later victims were to $7,500 each. In the November case the victim received $12,000. The lender was required tocreate a fund to compensate […]


On May 31st the Department of Justice settled a fair lending case with Sun Trust Mortgage. The case was completely typical. The case: > Began with a referral from the bank’s regulator – the Federal Reserve Board. > Involved discrimination against black and Hispanic borrowers. > Involved pricing discrimination resulting from unguided lender discretion. DOJ continues to very active in this area. During the past few years DOJ has averaged about seven cases per year. […]

ABA RCC – Day 4 – June 13

Orlando, FL It is regulator day in Orlando. The general session involved all of the regulatory agencies on a panel. The topic was The Continuing Changing Face of Compliance Oversight. It was a very sweet session. All of the regulators said the right things but didn’t provide any significant insight into the regulatory process. Breakout sessions were available for banks to listen to their regulators answer presubmitted, preselected answers.┬áThe final general session was entitled Getting […]

ABA RCC – Day 3 – June 12

I started my day with another dose of UDAAP. Then proceeded to a very emotional general session with representatives of Arvest Bank detailing it’s response to the tornado that devastated Joplin, MO during May of 2011. The presentation provided a startling reminder of the importance of disaster recovery planning. I got an update on HMDA/CRA and on appraisal rules and finished the day with a session for big banks entitled When Disclosures are Not Enough. […]

ABA RCC – Day 2 – June 11

Orlando, FL Two major themes of the conference involve UDAAP and mortgage loan disclosures. UDAAP is a game changer. The task of assessing UDAAP risk is massive. It involves every product and every aspect of product throughout the product life cycle. Many bankers appear to be in shock at this reality. Numerous speakers confirmed what we already knew – the mortgage changes are huge. Raj Date, Deputy Director of the CFPB and former Riverboat Pilot […]