03/26/2012
I'm not finding too much written about ECOA Section 704B (collect and report information concerning credit applications made by women or minority-owned businesses and by small businesses). Has there been a guidance about how to collect the data, what form to retain it and how to report it to the CFPB?
03/19/2012
I've been looking at the Reg B Section 704B of the ECOA. Are all financial institutions required to obtain this information on any type of loan by women-or minority-owned businesses and small businesses? If we have dealer loans for motor vehicle dealers, do we need to make sure they do this?
02/06/2012
Does the FACT act apply to commercial loans?
01/23/2012
Related to the Reg B ECOA changes to adverse action notices. If using a consumer reporting agency like ChexSystems that also gives you a score and uses credit information, should you be disclosing their score and range of scores and listing the items that adversely effected their score on the notice when denying a deposit account?
11/14/2011
What is the address for the OCC that we should use for the ECOA Section on our Adverse Action? I am unable to find it on the OCC website. We are a Federal Savings Bank, and as of July 21st, we will be under the OCC.
08/15/2011
According to the Reg B ECOA proposal, does the adverse action notice pertain to deposit accounts if they use a credit report/scores to open an account?
09/20/2010
If we are freezing all HELOC accounts that have adverse credit, what notice has to be provided to the customer and when? We disclosed the bank's ability to do so in the initial disclosure.
08/03/2009
Are risk mitigation programs such as collection rewrites and extensions subject to ECOA, and Reg B?
06/22/2009
ECOA/Reg B has certain time frames in which we are required to notify applicants of our decision. What I am unclear about is how ECOA defines a completed application. Is it one in which all requested conditions have been received as opposed to receipt of a completed form 1003? Is the period for making a decision on a loan based upon the date the borrower applied or based upon the date all conditions were received for review? The Reg B Notice of Incompleteness references the inability to make a credit decision. Does Reg B require receipt of all required conditions before a credit approval can be made?
06/15/2009
Under ECOA does determination of joint vs. individual credit apply to all loans, or just to consumer loans?