Does Reg B require government monitoring?
Does Reg B require government monitoring?
A frequent question we get is whether a financial institution must collect government monitoring information (GMI) in accordance with Reg. B, HMDA, or both. B generally prohibits a creditor from collecting information on an applicant’s race, color, religion, national origin, or sex.
What is covered by Regulation B?
Regulation B prohibits creditors from requesting and collecting specific personal information about an applicant that has no bearing on the applicant’s ability or willingness to repay the credit requested and could be used to discriminate against the applicant.
Does Reg B apply to deposit accounts?
Answer: Regulation B applies to credit products – so the answer would be no, as neither the regulation nor the commentary addresses the application of adverse action to non-credit products. However, the amended Section 615(a) of the FCRA would apply to any type of adverse action (deposit accounts, insurance, etc.)
What does an application mean under Regulation B?
Under Regulation B, an “application” means an oral or written request for an extension of credit made in accordance with procedures used by a creditor for the type of credit requested.
When do I need to collect GMI under Regulation B?
Regulation B’s collection requirement only applies to applications primarily for the purchase or refinancing of an applicant’s primary residence (1-4 family dwelling) that will be secured by that same dwelling. It’s pretty easy to see that your lenders are going to need to be retrained if these changes affect your institution.
What are the prohibited practices in regulation B?
Prohibited Practices Regulation B contains two basic and comprehen sive prohibitions against discriminatory lending practices (section 202.4): • A creditor shall not discriminate against an applicant on a prohibited basis regarding any aspect of a credit transaction.
What is the purpose of regulation B of the CFPB?
Regulation B also requires creditors to notify applicants in writing that copies of all appraisals will be provided to them promptly. The statute provides that its purpose is to require financial institutions and other firms engaged in