Regulatory Practice Letter January 2013 RPL 13-01

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1 Regulatory Practice Letter January 2013 RPL Fair Lending CFPB Annual Report and Supervisory Highlights Executive Summary In December 2012, the Bureau of Consumer Financial Protection ( CFPB or Bureau ) released its first annual Fair Lending Report. The report offers an overview of the Bureau s fair lending program, and describes the work of the CFPB s Office of Fair Lending and Equal Opportunity ( Office of Fair lending ) and its Office of Enforcement in this area during its first year of operations (July 21, 2011 and July 20, 2012). The report further indicates the CFPB is still in the process of building its supervisory program for fair lending and expects the contribution to ensuring compliance with fair lending laws and promoting access to credit will increase as the program progresses. The CPFB separately issued the first edition of its Supervisory Highlights ( Highlights ) which outlines the Bureau s examination work, critical concerns identified through that work, and the remedies that it obtains for consumers who have suffered financial or other harm. The current Highlights covers the period between July 21, 2011 and September 30, It identifies an effective compliance management system ( CMS ), which includes fair lending CMS, as a critical component of a well-run financial institution, adding that the fair lending policies, procedures and internal controls should be established to ensure compliance with fair lending laws in all relevant lines of business. Deficient fair lending compliance programs were listed among the critical concerns specifically identified by examiners. Background The Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act ) gives the CFPB supervisory, enforcement, and rulemaking authority over the Federal consumer financial laws, including fair lending laws. In particular, the CFPB has authority over the Equal Credit Opportunity Act, ( ECOA ) which prohibits discrimination against applicants in any type of credit transaction including mortgages, car loans, student loans, and credit cards, among others. The CFPB also has authority over the Home Mortgage Disclosure Act ( HMDA ), which requires specified mortgage lenders to annually collect and report mortgage lending data in order to: determine whether institutions are serving the housing needs of their communities; aid in targeting public investment; identify possible discriminatory lending patterns; and, enforce fair lending laws. Section 1031 of the Dodd-Frank Act specifically authorizes the CFPB to take enforcement actions against large financial institutions and nonbank financial services

2 providers under its supervisory authority to prevent them from committing or engaging in unfair, deceptive or abusive acts or practices ( UDAAP ) in connection with any consumer transaction or the offering of a consumer financial product or service. The CFPB is further authorized to write rules to identify UDAAP, including requirements for preventing such acts or practices. The Dodd-Frank Act introduced the term abusive. The Dodd-Frank Act requires the CFPB to establish the Office of Fair Lending within the CFPB, and charges the office with ensuring that the Bureau provides oversight and enforcement of Federal laws intended to ensure the fair, equitable, and nondiscriminatory access to credit for both individuals and communities that are enforced by the CFPB, including the ECOA, HMDA and the Truth-in-Lending Act. Among other things, the CFPB must report to Congress on topics that raise fair lending-related issues, including credit scoring (related reports released September and December 2012), and reverse mortgages. The Bureau must also examine whether Federal regulators and the public have access to sufficient information to determine lender compliance with fair lending laws. The CFPB s supervision program assesses compliance with Federal consumer financial laws and regulations by large insured depository institutions, including banks, thrifts, and credit unions with assets over $10 billion, and their affiliates and service providers, as well as nonbank financial services providers such as mortgage lenders and brokers, payday lenders, private education lenders, and the larger participants of certain consumer markets as identified and defined by the CFPB (to date, consumer reporting and consumer debt collection), and their service providers. Description Fair Lending Report The CFPB s Office of Fair Lending has the goal of ensuring a consumer finance marketplace where individuals and communities have fair and equal access to financial products and services, product pricing reflects risk and value, and terms and conditions are clear and nondiscriminatory. The Office of Fair Lending employs a variety of tools, including supervision, enforcement, consumer education and engagement, the study of consumer financial markets, empirical research and analysis, and rulemaking to achieve this mission. The Bureau s first annual Fair Lending Report outlines the following accomplishments through July 20, 2012: Establishment of the Office of Fair Lending and Equal Opportunity within the Division of Supervision Enforcement and Fair Lending, along with the recruitment of a diverse and highly-qualified fair lending team. The office employs individuals with expertise and experience, from the Federal prudential regulators, the United States Department of Justice ( DOJ ), the United States Department of Housing and Urban Development, the Federal Trade Commission, state attorneys general offices, local human relations commissions, civil rights organizations, and financial services providers.

3 Commencement of the CFPB s fair lending supervision program, and completion of various levels of fair lending reviews at bank and nonbank institutions offering a variety of lending products. Supervisory examinations of large banks and nonbank financial entities focus on risk to consumers and place the highest importance on identifying any violations of Federal consumer financial laws and eliminating any resulting harm to consumers. CFPB expects regulated entities under its jurisdiction will have effective CMS, including effective fair lending CMS, which are adapted to the institution s business strategies and operations. CFPB Compliance Bulletin (Fair Lending) reaffirms the doctrine of disparate impact remains applicable to the supervision and enforcement of the ECOA. The Office of Fair Lending supports CFPB examiners in activities for banks and nonbanks ranging from assessments of the institutions fair lending CMS to in-depth reviews of products or activities that may pose heightened fair lending risks to consumers. Commencement of the CFPB s fair lending enforcement program, and initiation of fair lending investigations. The CFPB has the ability to conduct investigations, file administrative complaints, and hold hearings and adjudicate claims through the CFPB s administrative enforcement process. The CFPB has independent litigating authority and can therefore file cases in Federal court alleging violations of fair lending laws under the CFPB s jurisdiction. The CFPB will also refer findings of certain ECOA violations to the DOJ. The Bureau s approach to identification of fair lending issues is data-driven and conducted in collaboration with the CFPB s Division of Research, Markets and Regulations, where Research has dedicated fair lending staff, and Markets are organized by product area and participate in consumer protection policy relevant to fair lending. Ongoing work on amendments to Regulation C, which implements HMDA, and planning for the amendments to Regulations B and Z, which implement the ECOA and TILA, respectively. In particular, the CFPB has begun work to: Promulgate rules concerning small, minority-, and women-owned business loan data collection and reporting required by ECOA as amended by the Dodd-Frank Act. Prescribe regulations under TILA to prohibit abusive or unfair lending practices that promote disparities among consumers of equal credit worthiness but of different race, ethnicity, gender or age. Completion of an empirical study and report to Congress on the use of cohort default rates ( CDRs ) in private education lending. The report examined the eligibility, underwriting, and pricing criteria used by private educational lenders, with a specific focus on the use of CDRs. CDRs have been used by private student lenders ( PSL ) as a proxy for a student s likelihood of repaying debt. The CFPB states that the use of CDRs at very low default levels is a fair lending concern because racial and ethnic minority students are disproportionately concentrated in schools with higher CDRs. Accordingly, use of CDRs to determine loan eligibility, underwriting, and pricing may have a disparate impact on minority students by reducing their access to credit and requiring those minority students who do meet the lenders eligibility

4 thresholds to pay higher rates than are otherwise available to similarly creditworthy non-hispanic White students at schools with lower CDRs. The CFPB indicates they are able to generally conclude that lenders consideration of CDRs in either school eligibility or underwriting and pricing criteria may reduce credit access and increase costs disproportionately for minority borrowers. Accordingly, use of CDRs may require further analysis by lenders to ensure compliance with fair lending laws. Ongoing collaboration and coordination with Federal and state partners; and Outreach to private industry as well as fair lending, civil rights, and consumer and community advocates through multiple meetings and events in Washington, DC and across the country. Supervisory Highlights Fall 2012 In the Fall of 2012, the CFPB released its first Supervisory Highlights, which the Bureau states would serve to apprise the public and the financial services industry about its examination program, including the concerns that it finds during the course of its completed work, and the remedies that it obtains for consumers who have suffered financial or other harm. The Highlights are also expected to signal to all institutions the kinds of activities that should be carefully scrutinized for compliance with the law. In the release, the CFPB states that an effective and comprehensive compliance management system is a critical component of a well-run financial institution, and suggests that a financial institution with a deficient CMS may be unable to detect its own violations, which would render it unaware of resulting harm to consumers and unable to adequately address consumer complaints. Fair lending compliance is considered a critical component to an effective and comprehensive CMS and deficiencies in fair lending CMS noted by CFPB examiners throughout the first year of operations have caused it to be identified in the Highlights as an area of critical concern. The CFPB expects every financial institution to establish fair lending policies, procedures and internal controls to ensure that it is operating in compliance with the ECOA and Regulation B in all of the financial institution s relevant lines of business. Fair lending programs should be commensurate with the size and complexity of a financial institution and its product lines of business. The Bureau suggests the following features are consistent with well developed fair lending compliance programs: An up-to-date fair lending policy statement; Regular fair lending training for all employees involved with any aspect of the institution s credit transactions, as well as all officers and Board members; Ongoing monitoring for compliance with fair lending policies and procedures; Ongoing monitoring for compliance with other policies and procedures that are intended to reduce fair lending risk (such as controls on loan originator discretion); Review of lending policies for potential fair lending violations, including potential disparate impact; Regular statistical analysis of loan data for potential disparities on a prohibited class basis in pricing, underwriting, or other aspects of the credit transaction, and including both mortgage and non-mortgage products, such as credit cards, auto lending, and student lending;

5 Regular assessment of the marketing of loan products; and Meaningful oversight of fair lending compliance by management and where appropriate, the financial institution s board of directors. Deficiencies in fair lending compliance programs identified by CFPB examiners over the time period July 21, 2011 to September 30, 2012 have included: A lack of a formal fair lending compliance system; and Inconsistent application of the compliance system among major product lines (i.e., sufficient for some product lines and excluded from other product lines); Actions taken by the CFPB included requiring financial institutions to: Provide remediation; Adopt comprehensive policies and procedures; Allocate resources to employee training and oversight; Review adverse action letters; Expand internal fair lending regression analyses; and Monitor compliance through reports and certifications. The publicly announced enforcement actions taken by the CFPB between July and December 2012 included violations of the ECOA (e.g., age discrimination, credit scoring models) as well as UDAAP. Note: The CFPB uses the term financial institutions throughout the Highlights document and does not make a distinction between insured depository institutions and nonbank financial institutions under its supervisory authority. Commentary Going forward, companies that originate, purchase, service, or invest in consumer loans (traditional mortgage-related and consumer lending such as auto and private student loans, and credit cards) now face heightened scrutiny of their fair lending controls by the CFPB, as well as bank regulators, DOJ, state enforcement agencies, consumer advocacy groups, and investors. CFPB examinations and investigations will be expansive (encompassing banks and nonbanks and service providers), consumer oriented and data driven. Consumer complaints will feature prominently in focusing industry concerns and driving investigations and related litigation. As a result, standard compliance checklists and testing are no longer adequate for managing the risks associated with fairness practices. Strong and comprehensive CMSs that consider consumer input are critical to successful compliance in this new environment. Fair lending compliance management systems must be commensurate with the size and complexity of a financial institution and its product lines of business, as well as comprehensively cover the activities of the financial institution, and its service providers and third party vendors. Financial institutions and nonbank financial service providers should begin to review their own fair lending policies, procedures and controls for consistency with the

6 Regulatory Practice features identified by the CFPB as contributing to a well-developed fair lending compliance program and make adjustments as appropriate. Marketing, compliance, risk management, lines of business and senior management and the Board should all participate in the review. Service providers and third party vendors should be evaluated using the same standard as used for the financial institution or nonbank financial services provider. In our experience, we have seen a number of institutions incorporate fair lending into overarching fair and responsible banking principles, as well as broaden their fair lending programs to span across and within lending products. In anticipation of CFPB fair lending examinations, some institutions have also expanded consideration of fair lending issues to include deposits, services and investments in their reviews. It is noteworthy that fair lending deficiencies and violations highlighted by the CFPB include specific practices that directly violate the ECOA (such as age discrimination or steering in lending activities) but also practices that, if deficient, can affect an individual s access to financial products and services, such as accurate data reporting pursuant to the HMDA, accurate data reporting pursuant to the Fair Credit Reporting Act (information provided to credit bureaus) and, with respect to credit reporting, taking action on disputes, correcting errors and deleting information, as appropriate, and maintaining credit scoring models that comply with the ECOA. This reflects the breadth of the CFPB s efforts to address consumer protection. Accordingly, institutions are expanding their fair lending testing to include the span of products they offer as well as over the entire product life cycles (e.g., pricing within and across dealers). Some institutions have implemented deeper model review processes for fair lending, as well as disparate impact analyses (e.g., impacts of CDR, expansion of model testing). Targeted file reviews for fair lending have expanded with a focus on the appropriateness of file documentation. With the CFPB s primary focus on consumer protection and the critical importance of fairness in compliance management, financial institutions and nonbank financial services providers should consider, as some already have, expanding their consideration of fair lending issues and a broadening of their fair lending monitoring and testing. Contact us: This is a publication of KPMG s Financial Services Regulatory Practice Contributing authors: Linda Gallagher, Principal: Amy Matsuo, Principal: Yuriy Tchamourliyski, Senior Manager: Earlier editions are available at: ublications/regulatory-practice-letters/pages/default.aspx ALL INFORMATION PROVIDED HERE IS OF A GENERAL NATURE AND IS NOT INTENDED TO ADDRESS THE CIRCUMSTANCES OF ANY PARTICULAR INDIVIDUAL OR ENTITY. ALTHOUGH WE ENDEAVOR TO PROVIDE ACCURATE AND TIMELY INFORMATION, THERE CAN BE NO GUARANTEE THAT SUCH INFORMATION IS ACCURATE AS OF THE DATE IT IS RECEIVED OR THAT IT WILL CONTINUE TO BE ACCURATE IN THE FUTURE. NO ONE SHOULD ACT UPON SUCH INFORMATION WITHOUT APPROPRIATE PROFESSIONAL ADVICE AFTER A THOROUGH EXAMINATION OF THE FACTS OF THE PARTICULAR SITUATION KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. The KPMG name, logo and cutting through complexity are registered trademarks or trademarks of KPMG International WDC

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