Latest Lending - Advertising Topics

Fair lending is more than mortgages

06/20/2021

The CFPB hasn’t been active in fair lending other than mortgages, correct, does this present any challenges?

AAN? We don’t make those loans.

06/13/2021

During the PPP loan programs we had many requests, but we were not participating? These are commercial requests and would be subject to Reg B. Were adverse action notices required?

Equal Opportunity Lender Notification

06/13/2021

On an advertisement for credit cards and nonmortgage lending, should Equal Opportunity Lender notification be included or only on mortgage related loan advertisements? I understand Equal Housing Lender should be present on anything pertaining to loans using homes as collateral.

Equal Opportunity Lender Notification

06/13/2021

On an advertisement for credit cards and nonmortgage lending, should Equal Opportunity Lender notification be included or only on mortgage related loan advertisements? I understand Equal Housing Lender should be present on anything pertaining to loans using homes as collateral.

Is small business data gathering coming?

06/13/2021

How might PPP loans trigger new data reporting on business loans?

Advertising Rate Sheet-"Limited Time Offer"

05/09/2021

We are creating a rate sheet to be used by local Realtors. It will provide the current rates for several types of loan products. Under our in-house loan category, Marketing would like to list "Limited Time Offer" as one of the bullet points. I recommended they provide an expiration date. Marketing wants to show that as follows - "Limited Time Offer. May Expire Without Notice." Since UDAAP is governed by perception of the reader what are your thoughts, I am still leaning toward a hard expiration date. What is required, or commonly done?

UDAAP penalties are costly

04/11/2021

How much "teeth" does UDAAP really have to penalize a bank

Redlining is real

02/07/2021

Is redlining real? It seems to be an antiquated type of violation.

FDCPA is important to banks

01/31/2021

Why am I concerned with the FDCPA since it applies to third party collectors?

Written Permission to Access Credit Reports Required

01/24/2021

Written Permission to Access Credit Reports Required