Just When You Thought It Was Safe - ECOA Part 2

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# With Flying Colors Podcast: Equal Credit Opportunity Act (ECOA) Part Two

## Episode Summary
In this episode, Mark Treichel continues his discussion with Joe Goldberg, diving deeper into the Equal Credit Opportunity Act (ECOA) and Regulation B. They focus on the second primary purpose of ECOA: encouraging the informed use of credit through adverse action notices.

## Key Points
1. Adverse Action Notices
- Purpose: Inform applicants of reasons for credit denial or less favorable terms
- Must provide specific reasons in detail
- Optimal to provide 3-4 main reasons for adverse action

2. Special Purpose Credit Programs
- Allow creditors to meet credit needs of specified classes of persons
- Different rules for for-profit and non-profit organizations

3. Department of Justice Referrals
- Required when there's reason to believe an institution has engaged in a pattern of illegal discrimination
- DOJ guidance available for identifying practices that may lead to referrals

4. New ECOA Section (Effective August 29, 2023)
- Requires collection and reporting of small business lending data to CFPB
- Applies to creditors with at least 100 originations to small businesses for each of the prior 2 years

5. Enforcement and Legal Actions
- NCUA enforces for federal credit unions
- Private actions allowed, including class actions

6. Compliance Best Practices
- Familiarize with ECOA and Regulation B
- Implement sufficient compliance management system
- Provide regular training for staff involved in lending
- Oversee third-party vendors
- Conduct self-testing and audits

## Resources Mentioned
- NCUA Fair Lending Guide
- NCUA Regulatory Alerts and Letters to Credit Unions
- Federal Consumer Financial Protection Guide on NCUA website
- CFPB website (consumerfinance.gov) - Fair Lending section

## Guest Information
Joe Goldberg: Attorney with 40 years of experience, former NCUA staff member, and consumer compliance expert.

## Hosted By
Mark Treichel