FAIR LENDING

Fair Lending and Discrimination

Department of Justice Fair Lending Cases:• United States v. Bank of America

• United States v. Countrywide Financial Corporation

• United States v. GFI Mortgage Bankers, Inc.

• United States v. Luther Burbank Savings

• United States v. Mortgage Guaranty Insurance Corp.

• United States v. SunTrust Mortgage, Inc.

• United States v. Wells Fargo Bank

$550,000,000

Fair Lending Regulations

Equal Credit Opportunity Act: Equal Credit Opportunity Act:

Race RaceColor ColorReligion Religion

Sex SexMarital Status

National Origin

HandicapAgePublic Assistance Income

National Origin

Familial Status

Equal Credit Opportunity ActEnacted in 1974

AdvertisingInquiriesApplications

Delinquent AccountsAccount Administration

Affects a credit transaction in:

Collections

Fair Housing Act

Enacted in 1968

Expanded protection from discrimination into home ownership.

Fair Lending Discrimination

Overt Discrimination

Disparate Treatment

Disparate Impact

Disparate Impact

The credit practice, on general overview, appears neutral and is applied equally, but has a disproportionately negative effect, or disparate impact, of discriminating against a protected class.

Fair Lending Compliance Program

Internal monitoring;Member complaint response;Independent testing and auditing; and,Third party due diligence.

Fair lending compliance program should include:

Integrated with product development, business acquisition, and marketing.

Training;

Fair Lending Testing

Membership Demographics

Self-testing

Credit Union Self Assessment

Statistical Analysis

Thank you for joining me for this overview of Fair Lending.