#Do students qualify for equal opportunity housing full
#Do students qualify for equal opportunity housing zip
#Do students qualify for equal opportunity housing free

#Do students qualify for equal opportunity housing zip

Do the credit union’s underwriting or pricing guidelines contain any unusual criteria that could have a possibly negative disparate impact on a protected class? (e.g., underwriting or price models that use ZIP codes.).

Does any aspect of the credit union’s credit operations appear to vary by any of the prohibited bases? Examples: (i) The credit union establishes most of its branches in predominately non-minority neighborhoods and does not have a presence in nearby minority neighborhoods or (ii) Spanish and English advertisements emphasize different credit products.

Note: When performing 1 and 2 above, pay close attention to the credit union’s compliance management policies and procedures with respect to the following:

Consult Part II (“ Compliance Management Review”) of the Interagency Fair Lending Exam Procedures (IFLEP) and apply the Compliance Management Analysis Checklist in the IFLEP Appendix.

Verify that ECOA compliance is effectively integrated into the credit union’s compliance management program.

Review the credit union’s overall compliance management program.

These examination procedures reference the Interagency Fair Lending Examination Procedures (IFLEP), which are followed during fair lending examinations.

To determine whether the credit union is in compliance with those requirements of ECOA that are set forth in Regulation B.

To determine whether the credit union discriminated against members of one or more protected classes in any aspect of its credit operations.

To determine whether the credit union has established policies, procedures, and internal controls to ensure that it is in compliance ECOA and its implementing Regulation B.

Reputation risk can occur when the credit union incurs fines and penalties as a result of failure to comply with ECOA.

#Do students qualify for equal opportunity housing full

You can find the full text of Regulation B here (opens new window)Ĭompliance risk can occur when the credit union fails to implement the necessary controls to comply with ECOA. You can find the full text of ECOA here (opens new window) In keeping with the broad reach of the statute’s prohibition, Regulation B covers creditor activities before, during, and after the extension of credit.

The purpose of ECOA is to promote the availability of credit to all creditworthy applicants without regard to race, color, religion, national origin, sex, marital status, or age (provided the applicant has the capacity to contract) because all or part of the applicant’s income derives from any public assistance program or, because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. This amendment to Regulation B also requires creditors to notify applicants in writing that copies of all appraisals will be provided to them promptly.

#Do students qualify for equal opportunity housing free

In January 2013, CFPB amended Regulation B to reflect the Dodd-Frank Act amendments requiring creditors to provide applicants with free copies of all appraisals and other written valuations developed in connection with all credit applications to be secured by a first lien on a dwelling. If you find ECOA violations at a FISCU and you feel the State Supervisory Authority is not properly addressing the issue, contact your supervisor. NCUA is not the primary enforcement authority for ECOA in federally-insured, state-chartered credit unions (FISCUs). NCUA continues to have authority to enforce ECOA for federally chartered credit unions under its supervision with $10 billion or less in assets. The Dodd-Frank Act granted rule-making authority under ECOA to the CFPB and, with respect to entities within its jurisdiction with over $10 billion in assets, granted authority to the CFPB to supervise for and enforce compliance with ECOA and its implementing regulation. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) transferred this authority to the Consumer Financial Protection Bureau (CFPB or Bureau). When originally enacted, ECOA gave the Federal Reserve Board responsibility for prescribing the implementing regulation.

), applies to all creditors, including credit unions. , which is implemented by Regulation B ( 12 CFR Part 1002 (opens new window) (You will be leaving and accessing a non-NCUA website. The Equal Credit Opportunity Act (ECOA), 15 U.S.C.