Is it disparate treatment to have a policy stating that the bank does not do loans for non-US citizens?
Are there any compliance requirements for lenders to consider in situations where a borrower is removed from the loan application during loan processing?
I recently attended the deposit compliance webinar on November 3. The presenter's presentation noted front line obligations of "protecting the customer's medical privacy." Can you please explain better this obligation and what regulation the presenter specifically was referencing? Is there any impact on this obligation via-a-vis the new health savings product?
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.
James Ballentine, ABA's Director of Housing, had an interesting observation at PCI's CRA and Fair Lending Colloquium.
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?
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.
Our town wants to improve a residential area, they are asking local banks to offer a special equity product to this program. We would like to participate in the program and feel it is CRA related. Any discrimination issues? The area is not low income and is not minority.
Some questions recently arose about our OD protection plans and how they affect certain accounts that we offer.1. Our senior age is 50. Should we raise that to 62 or do we need to charge them the same for club checking that includes OD protection that we do for our other club members? 2. How does Reg Z affect the OD repayment plan? We offer customers 3 or 6 months to repay us.
We are in the process of implementing an automated overdraft protection service. As a courtesy, the Fair Lending folks at the FDIC spoke with us regarding "guidance" on this service. Specifically, they told us that if we have any checking products that are age-based (such as 50 years plus checking) that has a waived service charge that we are discriminating against all other accounts holders that have an account that is not aged base and has a service charge or a minimum balance requirement. The violation would fall under ECOA. We were told the only way that we would be in "guidance" would be if the aged based account was 62 years plus. We asked them to site specifically "where" in the Reg B or in the joint guidance that this is stated. Apparently this is very broad guidance. Has anyone else come up against this situation or been written-up in an exam for this? Any advise as to our next move?