All in Regulation B

Interagency Statement on Special Purpose Credit Programs Under the ECOA and Reg B

Adam Witmer
Regulatory Update, Regulation B, Fair Lending

On 2/22/2022, the FRB, FDIC, NCUA, OCC, CFPB, HUD, the DOJ, and the FHFA issued an interagency statement to remind creditors of the ability under the Equal Credit Opportunity Act (ECOA) and Regulation B to establish special purpose credit programs to meet the credit needs of specified classes of persons. The statement focuses on the special purpose credit options under ECOA and Regulation B, which have been publicly committed by many financial institutions to better serve underserved communities.

VIDEO: Are Changes Coming to Overdraft Programs?

VIDEO: Are Changes Coming to Overdraft Programs?

Adam Witmer
Regulatory Update, Regulation B

In this Compliance Clip (video), Adam shares some interesting hints of change that relate to overdraft protection programs. While nothing has been formally planned to be changed, this video shows several actions by the regulators which could be a foreshadow to changes with guidance for overdraft protection programs. If your organization has an overdraft protection program, you won’t want to miss this 7 minute video. A transcript of this video is now available.

VIDEO: Inquiry as a Factor on Adverse Action Notices

VIDEO: Inquiry as a Factor on Adverse Action Notices

Adam Witmer
FCRA, Regulation B

In this Compliance Clip (video), Adam answers a unique question about listing inquiries as a factor in the adverse action notices. Specifically, the question is whether or not creditors are required to include the number of inquiries in the list of factors affecting the credit score if it is the fifth key factor. The answer to this question will come from the FCRA and Regulation B, but specifically from the preamble to the July 15, 2011 Regulation B final rule. A transcript of this video is now available.

VIDEO: Credit Report Fees and Fair Lending

VIDEO: Credit Report Fees and Fair Lending

Adam Witmer
Fair Lending, Regulation B

In this Compliance Clip (video), Adam talks about how credit report fees can relate to fair lending. In particular, Adam describes how differences in credit report charges may lead to a fair lending violation under Regulation B. While this has been a known issue for decades, it seems this topic has resurfaced a bit, so feel free to share this with anyone on your lending team.

VIDEO: Executive Summary on CFPB Proposal for Small Business Data Collection

VIDEO: Executive Summary on CFPB Proposal for Small Business Data Collection

Adam Witmer
Compliance Management, Fair Lending, Regulation B

In this Compliance Clip (video), Adam provides a quick executive summary of the CFPB’s recent proposal to amend Regulation B, which will require small business data collection and reporting - much like HMDA - for many financial institutions. As this rule will have a significant impact on financial institutions, it is important to understand the direction this proposal is headed in regards to who might be required to report and what this rule is going to require. This video is a MUST WATCH for all compliance officer, senior lenders, and those who may be required to implement this new rule. (NOTE: Feel free to share this video with those in your team who may need to have this information as this video is free to all.)

CFPB Proposes Small Business Data Collection Rule

Adam Witmer
Regulatory Update, Regulation B

It’s finally here. After a decade of anticipation of the Dodd-Frank Act’s requirement for the CFPB to establish small business data reporting, the CFPB has issued a proposal on how they plan to implement the requirement of the Dodd-Frank Act.

As you would expect, this topic will be covered in our Fall 2021 Quarterly Compliance Update, which should be available in mid-to-late October, 2021.

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.

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