All in Regulation B

VIDEO: Adverse Action for Declined Counter Offer

VIDEO: Adverse Action for Declined Counter Offer

Adam Witmer
Regulation B

In this Compliance Clip (video), Adam discusses the nuances of adverse action notices in the context of declined counteroffers for commercial loans. He explains the regulatory framework under Regulation B and the implications for lenders when an applicant withdraws their application after a counteroffer is declined.

CFPB Takes Action Against Draper & Kramer Mortgage for Redlining Violations

Adam Witmer
Regulatory Update, Regulation B

On January 17, 2025, the CFPB took action against Draper & Kramer Mortgage Corporation for discriminatory mortgage lending activities that discouraged homebuyers from applying to Draper for homes in majority-Black and Hispanic neighborhoods in the greater Chicago and Boston areas. CFPB Director Rohit Chopra said that the Bureau’s proposed order bans Draper from mortgage lending for five years and ensures that the company pays for its unlawful discrimination.

VIDEO: Filling Out the 1071 Data Collection Form

VIDEO: Filling Out the 1071 Data Collection Form

Adam Witmer
Regulation B

In this Compliance Clip (video), Adam answers a question about who can fill out the 1071 data collection form when there are multiple principal owners of a business opening an account. I other words, can one principal owner answer the demographic questions on behalf of the other principal owners, or do they each need to answer their own questions?

VIDEO: Denial Reasons for Not Meeting a Minimum Credit Score

VIDEO: Denial Reasons for Not Meeting a Minimum Credit Score

Adam Witmer
Regulation B, Adverse Action

In this Compliance Clip (video), Adam discusses what denial reasons should be used when an applicant does not meet a minimum credit score. He explains that there are sometimes reasons that are easily listed on the Adverse Action notice, but other times, the reasons for a low credit score may not be as clear. If your financial institution has a minimum credit score requirement, this video is a must watch.

Kentucky Judge Blocks Nationwide Enforcement of 1071 Final Rule

Adam Witmer
Regulation B, Regulatory Update

On September 15, 2023, the ABA Banking Journal published an article announcing a Ketucky federal judge’s nationwide injunction blocking enforcement of the CFPB’s Section 1071 final rule until the U.S. Supreme Court rules on the constitutionality of the bureau’s funding structure. The said injunction is separate from the ruling issued by a Texas judge in July, which only applied to ABA and Texas Bankers Association members.

VIDEO: 1071 Voluntary Collecting & Reporting

VIDEO: 1071 Voluntary Collecting & Reporting

Adam Witmer
Regulation B

In this Compliance Clip (video), Adam answers the question on whether a non-covered financial institution can voluntarily collect information on covered applications from a small business pursuant to the 1071 Final Rule. Adam explains the answer by discussing the different situations that the CFPB has provided through the Small Business Lending Rule Small Entity Compliance Guide. A transcript of this video is now available.

1071 Resources Available NOW and Coming Soon!

Adam Witmer
Regulation B

On 3/30/23, the CFPB released the long anticipated rule that implements section 1071 of the Dodd-Frank Act. This rule will require certain lenders to report information about the small business credit applications they receive, including geographic and demographic data, lending decisions, and the price of credit. As you would expect, we are working on a number of resources to assist our members in understanding if this rule applies to them and, if so, help them implement this rule within their organizations. Click the link to this article to see the 1071 resources we currently have available as well as those we are working to create.

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