Equal Credit Opportunity Act (ECOA)/ Reg B
Reg B covers
Consumers and business
When is the upfront notice of rights required under reg b?
Within 3 business days of application or identification of a covered transaction
What is the record retention period under reg b for small business?
12 months
What is the retention policy under reg b for consumer records?
25 months
Prohibited Bases under ECOA only
Age, marital status, receipt of public assistance, exercise right under the consumer credit protection act
What must a creditor retain per reg b?
Application, government monitoring information, written or recorded information used, notice of action, SSR and any written statements alleging violation of reg b.
When should a person's intent to be a joint applicant?
At the time of application
Under reg b what is required for providing an appraisal?
Credit request secured by a 1st lien on a dwelling
Credit scoring systems can be of two types?
Empirically derived or judgmental evaluating system
When are written applications requires?
For loans to purchase or refinance a principal dwelling secured by the dwelling
Under reg b, multiple applicants must be provided adverse action?
Only the primary applicant needs to be notified
What are the 5 prohibited basis for ECOA and FHA
Race, sex, national origin, religion, color
When should disclosures be provided under reg B?
Upon completion or at least 3 business data prior to consummation
Can a creditor inquire about immigration status and permanent residency under reg B
Yes
Reg B is cradle to grave regulation?
Yes
Are appraisal reports sent to the borrower? And is this required by Reg b.
Yes, yes
Which of the following bases is the most acceptable method of delineating a bank's CRA assessment area(s)? a.) Existing boundaries such as MSAs or counties in which the bank's office(s) is(are) located b.) The bank's effective lending territory (i.e., where it makes a substantial portion of its loans) c.) The zip codes that are included within a radius of the bank's office(s) d.) The area(s) assigned by the bank's primary regulator
b.) The bank's effective lending territory (i.e., where it makes a substantial portion of its loans)