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#2251259 - 03/25/21 06:42 PM Reg. B - Expanded Prohibited Basis
KeKe Offline
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Joined: Sep 2015
Posts: 36
Midwest
Is anyone updating their consumer facing materials to address the recently issued CFPB expansion of prohibited bases to include "sexual orientation and gender identity?"

If I am reading the interpretative rule correctly it states that there are no requirements to revise disclosures.

I participated in a webinar on regulatory changes and they suggested revising policies, procedures, updating training materials and legal disclosures and all other consumer-facing materials.

Is the Equal Housing Poster being updated?

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#2251264 - 03/25/21 06:50 PM Re: Reg. B - Expanded Prohibited Basis KeKe
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 76,096
Galveston, TX
If they suggested adding disclosure requirements beyond what the CFPB said - I hope you didn't pay a lot for this webinar. As far as internal written procedures and training - I would hope this had been covered already regardless of the law or regulation.
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#2251338 - 03/26/21 08:12 PM Re: Reg. B - Expanded Prohibited Basis KeKe
Andy_Z Offline
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The CFPB issued an interpretive rule. They did not have to follow notice and comment requirements because it is not a new requirement or regulatory change, it is an interpretation of an existing requirement.

If your bank has specific examples of what is covered in policies, procedures and especially in training materials, expanding those - especially training - would be advised but a boilerplate statement that "we comply with X," and X is a broad issue like "we do not consider sex in any phase of a loan process," then modifications are not required. Training staff that this is definitely a part of sex, that's all that's really needed.
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