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;
- General rules;
- 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;
- Monitoring information;
- Appraisal rules;
- And more.
Questions and Answers
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