05/29/2006
Would direct marketing to seniors for reverse mortgages be in violation of ECOA due to advertising to a particular group of people, in this case, age-related?
05/01/2006
A person recently applied for a renovation loan in one of the parishes (counties to all those of you outside Louisiana) hardest hit by the devastation of Hurricane Katrina and the subsequent flooding from the levee failures. One of our loan officers denied the request based on, "We do not feel comfortable lending in St. Bernard Parish at this time." Is this a valid reason for denial? It is not one of the prohibited bases, and it is not redlining like back in the day, as St. Bernard Parish is a vastly predominately white area. The denial is based on the total destruction of the parish, and the uncertainty of its regeneration. One of the issues is that St. Bernard Parish also suffered from a severe oil leak from one of its refineries that affected many properties. Secondly, a large number of people from St. Bernard Parish have already permanently moved out of the parish and have established residences elsewhere.
03/27/2006
The financial institution I am at keeps copies of drivers licenses with the applicants' loan documentation. Should they be concerned about possible discrimination issues, because there is a picture of the applicant present when an application is processed for approval?
03/13/2006
We want to start a promotion where we notify customers that they have been pre-approved for a Home Equity loan, what guidance can you provide and what regulation should I look at?
01/30/2006
Can you offer a special checking account to a select group of people, ie: they all work at the same place, without discriminating against other customers if they are not employed by the same company?
01/01/2006
A key element of measuring risk is determining the amount and priority of risk. With compliance regulations, some risks are very difficult to manage in a way that reduces or eliminates risk.
12/01/2005
James Ballentine, ABA's Director of Housing, had an interesting observation at PCI's CRA and Fair Lending Colloquium.
10/01/2005
The HMDA data of 2004 is not very different from the information collected in 1974. African Americans are turned down for loan applications significantly more often than whites.
10/01/2005
The 2004 HMDA data is finally out and the numbers show what we expected and feared: Black Americans fare less well in the mortgage market than non-Hispanic whites. Now what?
08/01/2005
Our bank is considering a "club account" marketed towards young professionals. I know on the lending side we have ECOA and fair lending to take into consideration, what areas of potential discrimination should we consider on the deposit side? I have read the question answered by Andy Zavoina entitled Is Free Checking for 50 and older an ECOA violation? Are there other regulatory areas to take into consideration?