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)