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Fair and Responsible Banking Committee
CBA's Fair and Responsible Banking Committee supports fair and responsible lending principles, opposes discrimination in the provision of retail financial services, and works to ensure that consumer protections laws are strong, effective and manageable for compliance operations. The Committee is composed of the top fair lending and compliance officers at the nation's leading financial institutions.
The job of fair lending compliance has become more complex in recent years because of the creation of the Consumer Financial Protection Bureau (CFPB), which is now responsible for implementing many of the laws applicable to fair lending, such as the Equal Credit Opportunity Act and Home Mortgage Disclosure Act. The Bureau also is the compliance supervisor for banks over $10 billion in assets. The expectation of compliance with unfair, deceptive, or abusive acts or practices (UDAAP) laws, also within the province of the CFPB, often falls on the shoulders of the fair lending compliance officers at banks, effectively expanding their responsibility from traditional fair lending to a broader responsible banking arena.
At the same time, traditional fair lending oversight has become more and more analytical, requiring sophisticated tools to prevent compliance problems. New areas are receiving greater scrutiny, including the servicing of loans and the loss mitigation efforts of banks dealing with the fallout of the economic crisis on housing. Lenders employing third party originators, such as auto dealers and mortgage brokers, continue to wrestle with the difficulty of fair lending oversight and the potential for liability.
Through CBA's Fair and Responsible Banking Committee, CBA communicates the changes in Washington to member banks, monitors how the current economic climate is affecting fair lending standards, and transmits the critical perspective of retail bankers back to regulators and lawmakers.