All in Regulation B

Address Updates for OCC Posters & Notices

Adam Witmer
CRA, Regulatory Update, Regulation B, Fair Lending

On 8/5/2021, the OCC issued Bulletin 2021-35 to inform national banks, federal savings associations, and other applicable branches/organizations of the appropriate names and addresses for certain notices. Specifically, the Bulletin provides the current addresses needed on notices/posters required by the Community Reinvestment Act (CRA), Equal Credit Opportunity Act, and the Fair Housing Act. Banks should make the appropriate changes to their notices and posters, if necessary, within 90 days of this bulletin’s date of issuance.

VIDEO: Reg B GMI on Refinance

VIDEO: Reg B GMI on Refinance

Adam Witmer
Fair Lending, Regulation B

In this Compliance Clip, Adam takes a deep dive into the world of government monitoring information (GMI) under Regulation B. If your financial institution recently became exempt from HMDA and you now collect GMI only under Regulation B - or maybe you have always been a Reg B bank - then you will want to check out this video. Basically, Adam answers the long-asked question of: Is GMI required under Reg B on a loan that is refinancing a loan that was not purchase money?

VIDEO: GMI for Construction Refinance

VIDEO: GMI for Construction Refinance

Adam Witmer
Regulation B

In this Compliance Clip (video), Adam answers a question about collecting government monitoring information (GMI) for a second construction loan replacing a first construction loan. This question is specific to Regulation B and applies to those financial institutions who are not HMDA reporters.

CFPB Issues Advisory Opinion on Special Purpose Credit

Adam Witmer
Regulatory Update, Regulation B

On 12/21/2020, the CFPB issued an advisory opinion related to special purpose credit programs (SPCPs) as it relates to uncertainty under Regulation B. The ECOA and Regulation B prohibit discrimination on certain prohibited bases in any aspect of a credit transaction, but they clarify that it is not discrimination for for-profit organizations to provide SPCPs designed to meet special social needs. In their release, the Bureau clarifies that they have issued this advisory opinion to clarify the content that a for-profit organization must include in a written plan that establishes and administers a SPCP under Regulation B. The advisory opinion also clarifies the type of research and data that may be appropriate to inform a for-profit organization’s determination that a SPCP would benefit a certain class of people.

CFPB Issues Outline of Proposals for Small Business Data Collection

Adam Witmer
Fair Lending, Regulation B, Regulatory Update

On 9/15/20, the Consumer Financial Protection Bureau (CFPB) issued an “Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 of the Dodd-Frank Act.” This release explains how the CFPB is currently working to implement Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that will create a requirement for financial institutions to compile, maintain, and report certain data on applications for credit from women-owned, minority-owned, and small businesses.

VIDEO: Reg B Data Collection for Ag or Commercial Loans

VIDEO: Reg B Data Collection for Ag or Commercial Loans

Adam Witmer
Regulation B

In this Compliance Clip (video), Adam answers a question for a member about Reg B data collection of government monitoring information (GMI) for agricultural loans. This abnormally long Compliance Clip lasts over 10 minutes and goes over three different scenarios. This clip would be great for any newly exempt HMDA reporter who will soon be transitioning to GMI collection under Reg B instead of DI information under HMDA.

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