Fair Lending
2001
Why are you here?
Everyone has contact with customers
You may be the first to be approached regarding a loan
Know who to refer the customer to
Show interest and respect for the customer
Communicate
Smile :)
Speak - follow up
e
Offer to help
Thank the customer
The Message
You like working here -
it’s a good place to be
It’s a good place for the customer to be
Know and understand the bank’s products and municate respect and interest
The Four Fair Lending Laws
Fair Housing Act (FHA-1968)
Equal Credit Opportunity Act (ECOA-1974)
Home Mortgage Disclosure Act (HMDA-1975)
Community Reinvestment Act (CRA-1977)
Equal Credit Opportunity ActGeneral Purpose
Promote equal availability to credit by all credit worthy applicants
Prohibited Bases
FHA
Race or color
Religion
National Origin
Sex
Familial status
Handicap
ECOA
Race or color
Religion
National Origin
Sex
Marital status
Age
Receipt of public assistance
Covered Aspects
Taking applications
Evaluations of apps
Extending credit
Credit Admin. & servicing
Collection activities
Loans to buy, build, repair, improve dwelling
Purchase or rental of residential dwellings
Selling, brokering, or appraising
ECOA FHA
Types of Lending Discrimination
Overt Discrimination
Disparate Treatment
Disparate Impact
Overt Discrimination
Openly or blatant discrimination on a prohibited basis
Expressing a discriminatory preference, even without acting on the preference
“We don’t like to make loans to------but”
Credit limits based on age
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