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CFT
Webinars are purely educational. Instructors are not permitted to sell any
products or services during the presentation.
Program
Content:
What?
Both
the Equal Credit Opportunity Act (ECOA) and the Fair Credit Reporting Act
(FCRA) contain requirements for providing notice of action taken. This
webinar reviews the requirements of both laws and covers common violations
and provides solutions.
Examiners
closely scrutinize denial notices for compliance with ECOA and FCRA
requirements. Adverse action violations are frequently cited in exam
reports. Items as simple as the failure to check a box or checking a box
that should remain unchecked are frequent violations.
Corrective
action can be painful. Pursuant to a consent order with its regulator, one
bank was required to search its records for two previous years to identify
loan applicants that never received, or who had received inadequate,
adverse action notices. The bank was required to send new notices to
affected applicants within seventy-five days from the date of the order.
This action was burdensome for the creditor, confusing for the denied
applicants, and completely avoidable.
Why?
Failure
to comply with adverse action requirements can lead to civil liability and
enforcement actions from the regulators. This webinar covers the proper and
timely handling of denial notices in accordance with ECOA/Regulation B and
FCRA. Participants receive a detailed manual that serves as a handbook long
after the program is completed.
Covered
Topics:
- The adverse action notice requirements of both the
Equal Credit Opportunity Act (Regulation B) and the Fair Credit
Reporting Act;
- How to complete the model adverse action form;
- The rules for providing notices to multiple
borrowers;
- The rules for determining who provides the notice
in situations with multiple creditors or a broker and an investor;
- Proper handling of counteroffers, and withdrawn and
incomplete applications;
- Timing rules for adverse action notices;
- How to select the correct reasons for denial;
- Rules for commercial loans;
- The differences between applications, completed
applications and inquiries, prequalifications and preapprovals;
- When an adverse action notice is needed for a
deposit account;
- Listing credit scores for adverse action versus the
HMDA LAR;
- Who is listed as the credit bureau where the credit
report is obtained from an aggregator who includes three credit scores
from three different companies; and
- Common errors in completing adverse action notices.
Who
Should Attend?:
The
program is designed for compliance officers, auditors and for those with
responsibility for completing adverse action notices. Please forward email to appropriate
person(s).
Instructor:
Jack
Holzknecht is
the CEO of Compliance Resource, LLC. He has been delivering the word on
lending compliance for 43 years. In 38 years as a trainer over 145,000
bankers (and many examiners) have participated in Jack’s live seminars and
webinars. Jack’s career began in 1976 as a federal bank examiner. He later
headed the product and education divisions of a regional consulting
company. There he developed loan and deposit form systems and software. He
also developed and presented training programs to bankers in 43 states.
Jack has been an instructor at compliance schools presented by a number of
state bankers associations. As a contractor he developed and delivered
compliance training for the FDIC for ten years. He is a Certified
Regulatory Compliance Manager and a member of the National Speakers
Association.
What
Is A Webinar?:
A
webinar combines the clarity of an audio teleconference with the
interactivity and visual presentation of the internet. All you need to
participate is a telephone and an internet connection. Even if you don't
have an internet connection, you can still participate in the audio
session. Listening to the program over the telephone and following the
written materials is an effective alternative!
Unable
To Attend?:
No
problem. You can purchase a recording of the webinar for future use. You
can choose from either an On-Demand Web Link (Good for 6 months from the
webinar date, unlimited use) or a CD-ROM (includes a paper copy of the
PowerPoint slides).
Viewing
Options (all options include applicable handouts):
All
options include applicable handouts. You can choose to pay by credit card
or be billed. Additional Live Webinar connections are $75 each.
Option 1: Live
Webinar and 7 Days OnDemand Video Playback - $265
Option 2:
OnDemand Video (six months access) - $295
Option 3: Live
and 6 Months of OnDemand Video - $365
Option 4: CD-ROM
Video (Includes OnDemand Video) - $345
Option 5: Entire
Package (all of the above) - $395
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