COMPLIANCE CLASS: Adverse Action Requirements
Adverse action notices are often a challenge for financial institutions for a number of reasons. First, the regulatory requirement for completing adverse action notices are quite extensive and are actually found in two separate rules: Regulation B and the Fair Credit Reporting Act. These rules require financial institutions to give a notice to applicants when “adverse action” is taken, and there are many little nuances of the rules that makes compliance sometimes challenging. Secondly, adverse action notices can be challenging for financial institutions as there are a lot of moving parts that can easily result in errors. Whether it’s a recent address change to the regulator contact information, or an error in completing the specific reasons for denial, errors can easily occur if those completing the adverse action notices aren’t experts in the corresponding rules.
To ensure compliance when completing adverse action notices, it is essential for banks, credit unions, and other lenders to have a comprehensive understanding of the notice requirements found in both Regulation B and the Fair Credit Reporting Act (FCRA).
Our Adverse Action Requirements program takes a deep dive into the requirements of both Regulation B and the FCRA when a loan application is denied, incomplete or withdrawn, or when unfavorable changes to the terms of existing credit arrangements are occurring. In this program, we review the adverse action requirements for financial institutions in great detail. Specifically, our program begins with an introduction and overview of the rules relating to adverse action notices. After this, our instructor reviews a few applicable definitions and general requirements of the rules. Next, our program reviews the delivery requirements of both Regulation B and the FCRA by answering questions like “who must receive a notice?” and “when is a notice required?” After that, attendees will review how the adverse action notice requirements relate to counteroffers, incomplete applications, and withdrawn applications. Our instructor then takes a very deep dive into the disclosure requirements, covering the specific nuances of how each part of the adverse action notice must be completed before discussing the importance of and what should be looked at during a secondary review process. Finally, our program concludes with several examples of common adverse action notices while also discussing related emerging risks.
The bottom line is that this program takes an intense look at the adverse action requirements for banks, credit unions, and other applicable lenders. Our goal with this program is to help attendees become somewhat of an expert - or at least a specialist - on the adverse action notice requirements, so that they are empowered to correctly complete or review adverse action notices in their organizations. With the risk of adverse action errors being so high due to both the complexity of the rules and the many moving parts of completing the form, this class is a great way to ensure that those completing adverse action notices know exactly what they are supposed to do.
This program would be good for anyone needing to understand how to complete or review an adverse action notice, including compliance officers, risk managers, compliance analysts, loan officers, loan processors, auditors, managers, and even assistants.
Continuing Education Credits
4.5 CRCM, CERP credits. ABA Professional Certifications is dedicated to promoting the highest standards of performance and ethics within the financial services industry. The Adverse Action Requirements program has been approved for 4.5 CRCM, CERP credits. This statement is not an endorsement of this program or its sponsor. Certification holders must report these credits at aba.csod.com.
Class Pricing
Regular: $399
ADD ON: “+ Unlimited” - Add a private portal for anyone in your organization to view this program for an additional $279. Access is still available for 60 days, so those in your organization must view the program during your 60 day access window. Limit of 5 total Certificates of Attendance, though anyone in your organization can view the program through the portal we set up. You will be contacted with information on the private portal sometime after purchase.
NOTE: If you would like to demo this class before you purchase it to make sure it's what you are looking for, just let us know and we can work something out.