06/03/2002
We have an affordable loan program that is specifically geared towards minorities, females, household incomes that are less that 80% of HUD's MSA Median Family Income, a property located in a low income census tract or that is considered mostly minority and a first time homebuyer that does not meet any of the above -- any of these individuals will receive an 1/8% rate reduction. Are there any fair lending/CRA issues that we need to be concerned about?
05/01/2002
With attention focused on privacy, patriotism, and related activities, there has not yet been action on the proposals to amend Regulation B. However, that proposal is very much alive and waiting.
03/04/2002
Borrower is a corporation with one shareholder. All business assets are pledged as collateral. Lender wants the spouse to also sign on loan docs, with the concern being that she may gain ownership of at least 1/2 assets should they divorce. Would asking her to sign be a violation of Reg B? If so, does the lender have a bona fide concern regarding assets or does the fact that the borrower is a coporation make this a non-issue? Flip side: What about if the borrower was a partnership or sole proprietorship and the spouse has no role in the affairs or function of the business? (e.g., farmer Bob who takes a loan secured by crops.) Lender wants to add wife to loan as a condition for the same reasons listed above. How should I advise my lender?
02/01/2002
The concept is not new. It is familiar to almost everyone. A cost benefit analysis lays the foundation for deciding whether doing something is a good idea.
11/05/2001
Can a bank deny someone credit based soley on the fact that the applicant is a permanent resident of the US but not a citizen?
10/10/2001
08/01/2001
When all of the slogans die down and the opinions fade into the invisible background, CRA comes down to money.
02/05/2001
We have a customer who has applied for a home loan but does not qualify because ofher credit history. Her brother has offered to help her by guaranteeing her loan. the loan officerwould feel better if he was co-borrower. What are the legal differences between a guarantor andco-borrower when it comes to trying to collect on a debt? and will there be a fair lending problemif we deny this loan because we insist on a co-borrower?
02/05/2001
Help! We just crossed the magic threshold of having 50 employees. I am told this makes us subject to the affirmative action laws and requirements. Are there some common mistakes that companies typically make in the affirmative action area? We don't want to get nailed.
01/01/2000
The most recent fair lending development comes, not from the U.S. Department of Justice ("DOJ") but from a "friendly" regulator, the Board of Governors of the Federal Reserve System ("FRB").