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ICB Credit: 2.5 CRCMDo the employees and officers at your financial institution recognize when Adverse Action is taken on consumer applications for accounts or for consumer credit? Do they understand the circumstances under which the Equal Credit Opportunity Act (ECOA) and Regulation B and/or the Fair Credit Reporting Act (FCRA) require that you provide a notice of Adverse Action, what form the notice must take, and what information it must include? Do they know when the institution must send applicants notices with their credit scores and related information?
It is critical that all your lending staff – consumer and commercial – and new deposit accounts personnel are aware of the applicable ECOA and FCRA requirements for your institution, to avoid potentially costly errors and possible fair lending violations.
Join BOL Guru David Dickinson as he covers the Adverse Action Notice compliance requirements and best practices under the Equal Credit Opportunity Act (ECOA) and Fair Credit Reporting Act (FCRA), including:
- Consumer notifications
- Non-consumer notifications
- Notices of incompleteness
- Counteroffers and counteroffer denials
- Indirect lending requirements
- Credit score notifications
- Multiple applicant requirements
- Timing requirements
- Record retention
- Fair lending hot spots
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the Center for Financial Training, the American Bankers Association National Compliance Schools and is a frequent speaker at the ABA’s Regulatory Compliance Conference. David is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.David and his wife Karen have 3 adult children (none of whom live at home!) & 3 cats (which Dave is allergic to). They live on a lake in Nebraska and when possible, Dave can be found fishing or in the water. David plays the guitar & piano and enjoys singing with Karen. Together they lead worship at their church.
Adverse Action Notices
Questions and Answers
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