All in Fair Lending

As more and more examiners are expecting fair lending training for the Board of Directors, it is important to ensure that training efforts meet the needs of directors of the Board.  Well effective board training can be similar to training for other employees of the financial institution, it is important to understand several unique factors necessary for effective director training. The following three tips can be used for providing fair lending training to the Board of Directors.

On 12/3/18, the Federal Reserve, FDIC, OCC, NCUA, CFPB and Department of Justice hosted a joint webinar on fair lending hot topics.  The webinar covered a number of topics including redlining, examination scoping, pricing risks, marital status discrimination, disability and maternity leave discrimination, a HMDA update, and a question and answer session.  Overall, the webinar did….

When a financial institution denies an application, Regulation B sets forth several requirements that must be met.  Among other things, financial institutions are required to notify an applicant of the denial and (as applicable) provide the applicant with a “statement of specific reasons” for denial.  One of the biggest challenges in providing the specific reasons for denial is determining which adverse action reasons should be listed on the denial notice. As Regulation B does not explain what reasons should be used, financial institutions benefit from creating an Adverse Action Reasons Chart. This article provides a sample adverse action chart that could be used by financial institutions.

Compliance requirements for CD secured loans are not typically a huge topic of discussion for compliance seminar speakers or article authors.  That said, one of our members suggested this topic (you know who you are!), and I think it is a great topic to write on from the perspective of CD secured loans, rather than just bringing up these loans when discussing applicable regulations (which is usually the way it happens). The truth is that most financial institutions (and regulators) just…

As compliance professionals, we have an opportunity to impact future rules and regulations by providing comments to proposed rulemakings.  This opportunity is actually built into the rulemaking process, and I can tell you from reading many final rules over the years that comments are at least considered and often addressed in final rules.  The truth is that comments can make a difference and, right now, we all have an opportunity to provide feedback (comment) regarding how disparate impact is evaluated under the Fair Housing Act.