How does fair lending impact commercial loans, which is not “consumer protection” controlled?
We don't make owner occupied mortgages, but do make business purpose loans for rental properties. Do we need to continue using the Equal Housing Lender logo in advertising?
Will Loan Production Offices help in fair lending if we decide to close branches?
The CFPB hasn’t been active in fair lending other than mortgages, correct, does this present any challenges?
How might national banks assessment areas be impacted by the new CRA rules?
What was the HMDA data problem from 2019?
Ever since CIP we started keeping copies of IDs in our files. Is this OK?
We had the 6 points of information for an application but lost track of the request and took too long to deny it as we were awaiting additional income information from the applicant. What can we do now?
The bank is considering a credit card promotion for a period of 90 days that will waive the annual fee for the life of the credit card. A customer must apply for the credit card during this time frame to be eligible. It will not be advertised externally. Must the credit card application be altered or can we leave the annual fee on the app in case other customers take the application with them? What other compliance requirements exist for this type of promotion?
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?