Regulations & Guidance

In today’s banking environment as soon as one big new regulation is implemented another pops up. Our compliance resources help your community bank stay one step ahead of the regulators.

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Compliance Question of the Week

Question: A review of the bank’s lending policy has determined that it needs to address directly fair lending, ECOA and Reg Z ability to repay. Is there any guidance on how to address this? And is there any guidance on structuring the policy(ies)?

ANSWER:

The agencies issued guidance to address how Regulation Z’s ability to repay and ECOA (fair lending) interact – particularly with regard to qualified mortgages. Some banks prefer to have what is called an umbrella policy on lending and then separate policies for lending compliance regulations.

If the bank chooses a single umbrella policy, ensure that each separate policy on each regulation related to lending is referenced in the policy, and kept in proximity (including its location e.g., computer folder, binder location).

Also, ensure that when one policy is updated, other related policies are also updated as applicable, and any references are revised accordingly. As always, report revisions to the board, and train as necessary and update monitoring procedures to reflect any revisions.

Reference: Interagency Statement on Fair Lending Compliance and the Ability-to-Repay and Qualified Mortgage Standards Rule, October 2013.

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