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ECOA, Reg B & Risk Mitigation

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Question: 
Are risk mitigation programs such as collection rewrites and extensions subject to ECOA, and Reg B?
Answer: 

Regulation B and the ECOA covers every aspect of a credit transaction:

Section 202.4 - General Rules

Paragraph 4(a)
1. Scope of rule. The general rule stated in Section 202.4(a) covers all dealings, without exception, between an applicant and a creditor, whether or not addressed by other provisions of the regulation. Other provisions of the regulation identify specific practices that the Board has decided are impermissible because they could result in credit discrimination on a basis prohibited by the Act. The general rule covers, for example, application procedures, criteria used to evaluate creditworthiness, administration of accounts, and treatment of delinquent or slow accounts. Thus, whether or not specifically prohibited elsewhere in the regulation, a credit practice that treats applicants differently on a prohibited basis violates the law because it violates the general rule. Disparate treatment on a prohibited basis is illegal whether or not it results from a conscious intent to discriminate.

First published on BankersOnline.com 8/03/09

First published on 08/03/2009

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