Providing Accurate & Timely Adverse Action Notices
Adverse action violations are frequently cited in exam reports. Corrective action can be painful.
This webinar reviews ECOA and FCRA adverse action requirements. It also covers common violations and solutions to common problems.
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. It also covers common violations and provides solutions to common problems.
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 then required to send new notices to affected applicants within 75 days from the date of the order. This action was burdensome for the creditor, confusing for the denied applicants and completely avoidable.
Failure to comply 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.
- 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;
- Proper handling of counteroffers, and withdrawn and incomplete applications;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;
- When a notice is needed for a deposit account; and
- Common errors in completing adverse action notices.
The program is designed for compliance officers, auditors and for those with responsibility for completing adverse action notices.
Jack Holzknecht, CRCM, is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 39 years. Jack’s career began as a federal bank examiner. He also headed the form and software division of a regional consulting company. He has developed and presented training programs to bankers in 43 states. He also developed and delivered training for the FDIC.
Kelly M. Owsley, CRCM, is Director of Training Services for Compliance Resource, LLC. Since 2000, she has worked for financial institutions ranging in asset size from $250 million to $3 billion. Kelly has worked in branch management, lending, product development and training. Recently, she served as VP of Compliance for a community bank where she was responsible for implementing and training all compliance related topics.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2 hours/session
Member price: $275.00 | Non member price $550.00
Member price: $295.00 | Non member price $590.00
Online: Visit the CBA Webinar Catalog
Mail: Click here and mail completed form with check payable to ConferenceEdge to: (Mail at least 10 days prior to event)
1516 Xavier St., Ste 500, Denver, CO 80204
Phone: Call ConferenceEdge at (877) 988-7526 (credit card payments only)
- Preferred Payment Method: Online
- Please register online or by phone when paying with a credit card
- Payment Must Accompany Registration – Invoices are Not Provided
Register online up to day of event. Earlier registration allows time to check your computer for an optimal experience.