Training Course
Syllabus:
This seminar is designed for attorneys, branch managers, credit analysts, loan department personnel, bankers, internal auditors and compliance officers.
This one-day session will provide consumer and commercial lenders with a practical look at the fundamental requirements of the Equal Credit Opportunity Act and its implementing regulation – Regulation B. From pre-application to proper credit denial procedures, we will review the key building blocks of a fair lending program. In addition, this session will attempt to apply the requirements of Regulation B to practical lending scenarios and provide the lender with practical tips on how to avoid discrimination pitfalls in daily lending transactions.
Topics to be covered include:
• ECOA In Perspective
• Credit Denial Practices – The Good, The Bad And The Ugly
• The Many Faces Of Lending Discrimination
• Recent Developments In Fair Lending
• Related Compliance Issues
• Common Violations
9:00 a.m. - 10:30 a.m.
I. ECOA In Perspective (Scope And Coverage)
This session will put the fair lending rules into perspective and highlight the impact within the financial institution.
A. Scope And Coverage Of The Rules
B. Understanding Prohibited Factors In Discrimination
C. Disparate Treatment vs. Disparate Impact (Generally)
D. Interplay Of Regulation B With Other Regulations Fair Lending Laws
10:30 a.m. - 10:45 a.m.
Break
10:45 a.m. - 11:30 a.m.
II. Credit Denial Practices – The Good, The Bad And The Ugly
This session will focus on the application process and review the regulatory “timeclocks” surrounding a lender’s duty to respond to applications properly.
A. What Is An “Application”?
B. Adverse Action Rules
C. Common Violations
11:30 a.m. - 12:00 p.m.
III. The Many Faces Of Lending Discrimination
Drawing from case law, enforcement actions, and client experiences, this session will illustrate how discrimination might look in a typical lending transaction and provide insights into how to prevent fair lending violations.
A. Disparate Treatment Cases
B. Policies That Result In Disparate Impact
12:00 p.m. - 1:00 p.m.
Lunch (On Your Own)
1:00 p.m. - 2:00 p.m.
III. The Many Faces Of Lending Discrimination (Continued)
Drawing from case law, enforcement actions, and client experiences, this session will illustrate how discrimination might look in a typical lending transaction and provide insights into how to prevent fair lending violations.
C. Illegal Prescreening
D. Discrimination In Marketing
E. Vicarious Liability: Lenders Beware
2:00 p.m. - 2:45 p.m.
IV. Recent Developments In Fair Lending
Fair lending compliance continues to be a priority for regulators. This session will highlight current issues in enforcement and will provide insight into emerging areas of concern.
A. Regulatory Update
B. Trends In Enforcement
C. Growing Areas Of Concern
2:45 p.m. - 3:00 p.m.
Break
3:00 p.m. - 3:30 p.m.
V. Related Compliance Issues
3:30 p.m. - 4:30 p.m.
VI. Common Violations
This session will highlight areas that are frequently ripe for violations, and provide active steps on how to avoid compliance pitfalls.
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