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?
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?
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.
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…