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#1357856 - 03/15/10 09:24 PM ODP & Reg B
compliancemom Offline
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Joined: Mar 2009
Posts: 22
West TN
Could branch office inconsistencies in how OD privilege is offered create Reg B or Fair Lending problems? The issue is simply that some branches push the product more than others so the number of customers with the plan varies widely between markets....
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Lending Compliance
#1357883 - 03/15/10 10:57 PM Re: ODP & Reg B compliancemom
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,893
Galveston, TX
The regulators address this in the 2005 ODP guidance document:

Equal Credit Opportunity Act

Under the Equal Credit Opportunity Act (ECOA) and Regulation B, creditors are prohibited from discriminating against an applicant on a prohibited basis in any aspect of a credit transaction. This prohibition applies to overdraft protection programs. Thus, steering or targeting certain consumers on a prohibited basis for overdraft protection programs while offering other consumers overdraft lines of credit or other more favorable credit products or overdraft services, will raise concerns under the ECOA.
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