Newsroom

December 08, 2021

Financial regulators discuss redlining risks, special purpose credit programs during fair lending webinar

financial regFederal financial regulators – including the NCUA – Tuesday hosted a webinar to discuss fair lending practices.

During the NCUA’s presentation, the agency analyzed Home Mortgage Disclosure Act (HMDA) data noting that, while the agency does not directly require credit unions to conduct any specific HMDA analysis, all credit unions that collect HMDA data could benefit in ensuring fair lending compliance. The NCUA also mentioned in relation to its supervisory priorities, that it anticipates examiners to look at fair lending in 2022.

Other agencies attending covered a wide variety of topics:

  • The Department of Justice (DOJ) highlighted their redlining enforcement initiative and recent related cases;
  • the Federal Housing Finance Agency (FHFA) gave brief report on data from the GSEs underwriting platforms, which reflected racial disparities in denial rates;
  • the Federal Deposit Insurance Corporation (FDIC) provided an overview on redlining risks and expectations regarding the Community Reinvestment Act;
  • the Federal Reserve Board (FRB) conducted an overview of artificial intelligence and machine learning, flagging potential fair lending risks for using these tools
  • the Department of Housing and Urban Development (HUD) provided a summary of a Chase Bank enforcement action regarding appraisal discrimination; and
  • the Office of the Comptroller of Currency (OCC) gave tips for conducting redlining risk assessments and what kinds of red flags might indicate higher risk in this area.

In addition, during the webinar the CFPB detailed special purpose credit programs and highlighted HUD’s recently released guidance clarifying that special purpose credit programs conforming with the Equal Credit Opportunity Act and Regulation B generally do not violate the Federal Fair Housing Act. The CFPB sees this as a “systemic tool” for expanding access to financial services, improving racial equity issues, and more.

View the agenda from the webinar here. NAFCU will continue to monitor these topics to ensure that credit unions have all the regulatory tools and knowledge necessary to succeed.