Latest Compliance - Discrimination Topics

Internal vs. External

Whether measured by the Fair Housing Act or the ECOA, fair lending is more than a quarter of a century old. In that quarter century, fair lending has passed through a number of stages.

The Bank Secrecy Act with the added momentum of the USA PATRIOT Act, requires financial institutions to scrutinize their customers and their banking activities.

There is no better indicator of how HMDA data will be used than the ideas expressed by members of the Federal Reserve Board's Consumer Advisory Council ("CAC").

In recent years, we have coined a variety of terms for high-cost, short term loans. The names can vary from late payment fees through overdraft protection to payday lending.

In the world of compliance, we sometimes face requirements that appear contradictory, what we like to call dueling regulations.

It is talked about in many contexts. It is a term tossed about without clear definition. It engenders fear and caution among lenders. It raises compliance concerns.

The U.S. Department of Justice is working hard at fair lending enforcement. This is not a concern that has faded into the background. Quite the opposite is true.

It's time. The Christmas or seasonal decorations have gone up and that means that HMDA reporting is just around the corner. You need to get two important projects going.