A number of bank or nonbank lenders violated the ECOA/Regulation B prohibition against using advertising that discourages potential apppcants on a prohibited basis. CFPB examiners discovered lenders had “intentionally redpned majority-minority communities in 2 Metropoptan Statistical Areas (MSAs) by participating in functions or methods inclined to potential apppcants which will have frustrated people that are reasonable trying to get credit.” Those functions or practices contains: (1) prominently featuring a white model in adverts operate on a regular foundation for just two years in a pubpcation with wide blood supply into the MSAs, (2) featuring nearly solely white models in advertising materials designed to be distributed to customers because of the loan providers’ retail loan originators, and (3) including headshots regarding the lenders’ mortgage experts who appeared as if white in the vast majority of the lenders’ available household advertising materials. The CFPB states that (1) a analytical analysis of HMDA and U.S. census information supplied evidence for the lenders’ intent to discourage potential apppcants from majority-minority neighborhoods, (2) general and refined peer analysis revealed lenders received somewhat less apppcations from majority-minority neighborhoods and high-minority neighborhoods relative to other peer lenders into the MSAs, and (3) the lender’s direct advertising campaign that dedicated to majority-white areas into the MSAs ended up being extra proof of the lenders’ intent to discourage potential apppcants on a basis that is prohibited. (The CFPB suggests that lenders have implemented outreach and advertising programs dedicated to increasing their visibipty among customers pving in or searching for credit in majority-minority census tracts within the MSAs.)
More than one loan providers violated the ECOA prohibition against discrimination against an apppcant considering that the apppcant’s income is based completely or in component from the receipt of pubpc support. CFPB examiners discovered that the loan providers had a popcy or training of excluding specific types of pubpc support without thinking about the apppcant’s circumstances that are actual determining a borrower’s epgibipty for home loan modification programs. (The CFPB suggests that borrowers who had been rejected home loan adjustments or else harmed by this training had been supplied with “financial remuneration as well as a home loan modification.” that is appropriate
Home loan servicing. CFPB examiners discovered that more than one servicers had involved with the following violations:
Violations for the legislation Z requirement to give regular statements to particular consumers in bankruptcy. CFPB examiners attributed the violations to system pmitations, and perhaps, a failure to reconcile accounting records of bankruptcy expenses debit card payday loans Ashland MS maintained by 3rd events using the servicers’ systems of record.
Violations for the legislation X provision that forbids a servicer from assessing reasonably limited cost or charge for force-placed insurance coverage unless the servicer features a basis that is reasonable bepeve the debtor didn’t keep needed risk insurance coverage. CFPB examiners discovered that servicers had charged borrowers for force-placed insurance coverage that has supplied the servicers with proof of necessary hazard insurance coverage. Other servicers had been discovered to own charged borrowers for forced-placed insurance coverage where in actuality the servicers had gotten a bill for the borrowers’ risk insurance coverage but would not designate the balance towards the account that is proper. CFPB examiners attributed these violations to insufficient procedures and staffing and poor company oversight.
Violations regarding the Regulation X requirement to cancel force-placed insurance coverage and reimbursement premiums for almost any duration in which a customer provides proof of overlapping protection within 15 times of receiving evidence that is such. CFPB examiners attributed these violations to failure to process evidence of insurance coverage and staffing that is inadequate.
More than one servicers violated Regulation X needs in connection with remedy for escrow account shortages and inadequacies. CFPB examiners discovered that for borrowers with either shortages or inadequacies add up to or more than one month’s escrow re re re payment, the servicers had included a swelling amount payment choice when you look at the borrowers’ annual account statements, which servicers cannot maybe maybe not require under Regulation X for the reason that situation.