Topic: Equal Credit Opportunity Act (ECOA)
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If we reject a customer’s deposit account application but offer an account without overdraft privileges, is that an adverse action?
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Equal Credit Opportunity Act (ECOA) As to the adverse action issues in offering second-chance checking accounts, the ECOA’s and Regulation B’s notification requirements do not apply to decisions on allowing a customer to open a depositary account. The regulations require notification of an adverse action only when a bank refuses to grant “credit,” which is…
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Can our bank advertise a program of home loans exclusively for members of specific professions, such as teachers, policemen, firefighters, and healthcare workers, or could this be viewed as unlawful discrimination?
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Assuming that it is not done inappropriately in other respects, your bank is not prohibited from advertising or offering a home loan program exclusively to a particular profession. The federal Equal Credit Opportunity Act and its corresponding rule, Regulation B, prohibit banks from discriminating in the extension of credit based on race, color, religion, national…
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Can a bank turn down a home equity credit application for no reason other than the applicant has a serious gambling problem? Our bank is in a small town and has all of the applicant’s financial information, but the credit is perfect, the home has value, and the income is there.
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Regulation B allows a creditor to consider “any information obtained” in connection with an application for credit, as long as the information is not used to discriminate against an applicant on a prohibited basis. We are not aware of any law or court decision that prohibits a creditor from considering an applicant’s gambling history. 12…