06/15/2009
How do I go about getting new CRA notices for our main bank and branches?
03/23/2009
Where can I find a list of all the notices with size requirements that must be posted in the bank?
01/26/2009
The bank is thinking about conducting a mass mailing of debit cards to all customers who do not currently have a card. I understand that this may be done so long as we follow Section 205.5 of Reg E. The question is, can we exclude customers age 70 and over from the mailing? All of our accounts have overdraft coverage. I am concerned that due to that fact, the regulators might construe the coverage to be incidental credit, which could potentially mean an age discrimination issue per ECOA. I know that the bank can offer a product that benefits persons over age 62. Do you think excluding those over 70 (or 62) would be a benefit or a detriment? Do you think we can exclude the customers over age 70? Do you think we could use Regulation B's definition of "open-end credit" to get around the "incidental credit" issue?
10/10/2008
06/30/2008
We have been told that when we have a joint application and we deny the credit we have to send separate adverse action notices to each applicant, is this true?
06/23/2008
Are there any sources that offer standard initial residential mortgage loan disclosures in Spanish? I'm looking for a GFE, TIL, ECOA, borrower's authorization and servicing disclosure.
11/19/2007
I’m trying to find out the new address that Fed member banks must use to submit an adverse action notice under ECOA effective date 10/29/07. Can you help?
09/03/2007
Are lenders required to give an ECOA disclosure if no adverse action is being taken on a loan?
05/21/2007
In the Guru Q&As Compliance Section of the Weekly Banker Briefing dated 3/25/2007, a question under the topic of <a href="http://www.bankersonline.com/compliance/guru2007/gurus_comp032607c.html">"Loan Denied to Illegal Alien-Adverse Action?"</a> piqued my curiosity. I agree with the gurus' assertion that an ECOA AAN is required and as credit is never pulled, obviously, FCRA is not a factor. I do, however, question the following: <ol><li>Isn't the OSC [202.6(b)(7)(1)] referring to resident and non-resident alien status, not ILLEGAL status? <li>If the FI is denying ALL ILLEGAL applicants, how does that have any bearing on National Origin? (Yes, I know, "ALL" is a huge word)</ol>Also, I'd make a call to ICE upon learning of the illegal status.
03/26/2007
A bank has made a decision not to make consumer loans to illegal immigrants. If during the course of obtaining information a loan officer determines that an applicant is an illegal immigrant and therefore denies the loan, is the bank required to send an adverse action notice to the applicant based on an incomplete application since not all information regularly obtained was considered, or is the bank even required to send a notice in this scenario?