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Fair Lending/Responsible Banking
Fair lending principles are embraced by CBA members. Regulatory enforcement, however, is an increasingly complex area of compliance, and has become even more challenging with the intense search at the state and federal levels for 'predatory lending' practices. To encourage self-evaluation, CBA helped establish a privilege for self-testing for fair lending compliance. CBA also is responding to new fair lending guidelines and protecting banks from unnecessary and burdensome small business data collection.
- January 27, 2016On Wednesday, January 27, 2016, CBA and other trade associations requested the U.S. Department of Defense (DOD) extend until March 1, 2016 its deadline for financial institutions to opt-in for access to the Pentagon’s Defense Manpower Data Center database (DMDC). The DMDC database allows lenders to verify military status for applicants applying for consumer credit other than a mortgage or...January 27, 2016The Credit Union National Association (CUNA) and its trade association partners are asking for relief from a fast-approaching deadline involving financial institutions' responsibilities to identify borrowers covered under the Military Lending Act (MLA). Beginning Oct. 3, lenders must determine the military status of all applicants for many forms of consumer credit. The MLA places certain...January 26, 2016January 26, 2016 The Honorable Brad Carson Acting Under Secretary of Defense (Personnel & Readiness) 3E989, The Pentagon Washington, DC 20301 Dear Secretary Carson, The undersigned Associations appreciate the Defense Manpower Data Center’s (DMDC) outreach and commitment to working with us and other stakeholders on issues related to the Military Lending Act (MLA) Database. Together, our...January 22, 2016The new Military Lending Act (MLA) regulations require banks to determine military status for applicants applying for consumer credit other than a mortgage or purchase money loan. Lenders who verify military status through the U.S. Department of Defense (DOD) database or a nationwide credit bureau will be provided a compliance safe harbor. By February 1, 2016, bankers must email dodhr.dodc-mb...January 22, 2016On Friday, January 22, 2016, in anticipation of severe winter storms, the OCC issued a statement authorizing national banks and other federal savings associations in potentially impacted areas to close, but cautioned them on their responsibility to consumers. The agency reminded banks of their obligations to aid financial institutions and consumers affected by the storm, and recognized the...January 12, 2016On Tuesday, January 12, 2016, the CFPB issued a construction loan factsheet providing an overview on how the TILA-RESPA Integrated Disclosure Rule (TRID) applies to these types of loans. At the outset, the Bureau expressly states TRID applies to most construction loans which are secured, closed-end consumer credit transactions. In contrast, open-end loans or those for a commercial purpose lie...January 12, 2016On Tuesday, January 12, 2016, President Obama delivered his final State of the Union Address in which he laid out a larger vision for the next five to 10 years. In his address, the President presented four big questions for the country to answer regardless of who is in control of the next Congress or White House: (1) How do we give everyone a fair shot at opportunity and security in this new...December 17, 2015The Federal Reserve has just raised its benchmark Fed Funds rate by 25 bp — after seven long years at rock bottom. Overall, banks are breathing a huge sigh of relief, with the expectation of higher loan yields and revenue. But deposit gathering bankers must now face the reality of how to set deposit rates in response to rising interest rates — and in light of significant changes in regulation,...November 4, 2015November 4, 2015 The Honorable Paul Ryan Speaker U.S. House of Representatives H-232, The Capitol Washington, D.C. 20515 The Honorable Nancy Pelosi Minority Leader U.S. House of Representatives H-204, The Capitol Washington, D.C. 20515 Dear Speaker Ryan and Leader Pelosi: The undersigned organizations urge the House to adopt the Neugebauer-Huizenga amendment to H.R. 22, the DRIVE Act, which would...October 30, 2015Hillary Clinton said a lot of things on The Late Show With Stephen Colbert this week about her economic proposals. But it was one comment, which her campaign aides say was unscripted, that might have the best potential to catch political fire: a call to rein in galloping ATM fees. The Democratic presidential frontrunner checked several progressive boxes in the Tuesday night appearance. She...