You undoubtedly realize that Fair Lending has been a hot topic for a number of years and that doesn’t seem to be changing anytime soon. That’s one reason that it’s important to note that the CFPB recently released its annual Fair Lending Report. Remember as well that we still have that Small Business Data Collection rulemaking looming. The Bureau hasn’t, as they make mention of it in the report – although they do seemingly continue to kick that can down the road.
In the report, the CFPB gives us some of the most frequently cited Regulation B and ECOA violations, such as Discrimination; Improperly asking or failure to ask for government monitoring information; improperly requiring spousal signatures; not providing an adverse action notice within 30 days or not providing all the required information within the notice; failing to maintain records of applications and any associated action taken notices; and failure to provide appraisal reports when required.
Hopefully, you can take this list of frequently cited violations and not only take comfort in the fact that others are facing challenges here but use it as a bit of a checklist as being some areas you may want to check into, to see how you’re doing. Especially if you have an exam coming up, the sooner, the better.
There’s a reason that these items are frequently missed – they’re not easy. The first step of course to getting something right is understanding what you have to do. To help you there, we have several webinars that will help you make sure you’re on the right track. We’re excited to bring you topics such as documenting joint intent and All About Fair Lending to not only help you know what to look for but also help you share the message with others. Remember, access to the recording of the webinar, as well as our written responses to all questions received, is included in your purchase price. We hope you’ll join us soon.