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FAIR LENDING

FAIR LENDING. Fair Lending and Discrimination. Department of Justice Fair Lending Cases: United States v. Bank of America United States v. Countrywide Financial Corporation United States v. GFI Mortgage Bankers, Inc. United States v. Luther Burbank Savings

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FAIR LENDING

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  1. FAIR LENDING

  2. Fair Lending and Discrimination Department of Justice Fair Lending Cases: • United States v. Bank of America • United States v. Countrywide Financial Corporation • United States v. GFI Mortgage Bankers, Inc. • United States v. Luther Burbank Savings • United States v. Mortgage Guaranty Insurance Corp. • United States v. SunTrust Mortgage, Inc. • United States v. Wells Fargo Bank $550,000,000

  3. Fair Lending Regulations Equal Credit Opportunity Act: Race Race Equal Credit Opportunity Act: Color Color Religion Religion National Origin National Origin Sex Sex Marital Status Handicap Age Familial Status Public Assistance Income

  4. Equal Credit Opportunity Act Enacted in 1974 Affects a credit transaction in: Advertising Inquiries Applications Account Administration Delinquent Accounts Collections

  5. Fair Housing Act Enacted in 1968 Expanded protection from discrimination into home ownership.

  6. Fair Lending Discrimination Overt Discrimination Disparate Treatment Disparate Impact

  7. Disparate Impact The credit practice, on general overview, appears neutral and is applied equally, but has a disproportionately negative effect, or disparate impact, of discriminating against a protected class.

  8. Fair Lending Compliance Program Fair lending compliance program should include: Training; Internal monitoring; Member complaint response; Independent testing and auditing; and, Third party due diligence. Integrated with product development, business acquisition, and marketing.

  9. Fair Lending Testing Credit Union Self Assessment Statistical Analysis Membership Demographics Self-testing

  10. Thank you for joining me for this overview of Fair Lending.

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