Your lenders and loan interviewers need to be intimately familiar with Reg B and the Equal Credit Opportunity Act’s requirements. Why? Because if they don’t know the law and the requirements, they are quite apt to violate them.
We read the occasional headlines about someone of one race (a protected class) getting a better rate than another when they seem equally qualified for the loan. Yes, that is discriminatory, whether it was intended or not. You hear less about a lender telling a pregnant co-applicant that her income won’t be included until she is back at work after having the baby, but this happens too and it can be discriminatory.
What we hear less about is the joint intent screw up, the loan interviewer who tells an applicant a loan can’t be made based on their scenario, and refuses an application and the commercial lender who doesn’t have time for Reg B because it is consumer protection and his borrowers are businesses. But getting joint intent matters, not denying an oral application matters, and knowing commercial applications are subject to Reg B matters, too. You should worry about these things, because bank management worries about them, as do your directors and your examiners.
In this two-hour session we’ll visit the major and minor aspects of Reg B to give you a firm understanding, of what rules apply and when. We’ll discuss:
The purpose and intent of the Reg, making compliance easier;
Prohibited bases for discrimination
Definitions with emphasis on an applicant and application;
When and what information may be obtained from applicants;
Rules on when to send/disclose adverse action;
Mr. Andy Zavoina, CRCM, is an Executive Vice President with the Glia Group, Inc., best known for its involvement with BankersOnline.com. He joined Glia and BOL in 2003.
Mr. Zavoina has been in finance and banking for over 39 years. Over 20 years were with a two-bank holding company that had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He has done loan workouts, has been a consumer, commercial and real estate lender and managed those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks.
Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He is a BankersOnline Guru. He also served on the Texas Bankers Association's Compliance Committee. He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers. He has written articles and lectured on compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace to local, state and national associations across the U.S. and teaches basic compliance and compliance management.
You can reach Andy on the Internet by using his e-mail address, email@example.com, or visiting http://www.bankersonline.com.
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