ICB Credit: 2.5 CRCM

What
Both the Equal Credit Opportunity Act and the Fair Credit Reporting Act contain requirements for providing notice of action taken. This two-hour webinar reviews the requirements of both laws. It also covers common violations and provides solutions to common problems.

Corrective action can be painful. Pursuant to a consent order with its regulator, one bank was required to search its records for two previous years to identify loan applicants that never received, or who had received inadequate, adverse action notices. The bank was then required to send new notices to affected applicants within seventy-five days from the date of the order. This action was burdensome for the creditor and confusing for the denied applicants.

Why
Failure to comply with adverse action requirements can lead to both civil liability and enforcement actions from the regulators. Learn the fine points of the proper and timely handling of adverse action notices in accordance with ECOA/Regulation B and FCRA. Participants receive a detailed manual that will serve as a continuing resource.

Upon completion of this program participants understand:

• The adverse action notice requirements of both the Equal Credit Opportunity Act (Regulation B) and the Fair Credit Reporting Act;
• How to complete the model adverse action form;
• The rules for providing notices to multiple borrowers;
• The rules for determining who provides the notice in situations with multiple creditors or a broker and an investor;
• Proper handling of counteroffers, and withdrawn and incomplete applications;
• Timing rules for adverse action notices;
• How to select the correct reasons for denial;
• Rules for commercial loans;
• The differences between applications, completed applications and inquiries, prequalifications and preapprovals;
• When an adverse action notice is needed for a deposit account;
• Listing credit scores for adverse action versus the HMDA LAR;
• Which credit bureau to list when the credit report is obtained from an aggregator who includes three credit scores from three different companies; and
• Common errors in completing adverse action notices.

Who Should Attend:
The program is designed for compliance officers, auditors , branches and frontline, and for those with responsibility for completing adverse action notices.