Fair Lending, UDAAP and CRA: Protecting Your Bank from Allegations of Fair and Responsible Lending Violations

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1 Fair Lending, UDAAP and CRA: Protecting Your Bank from Allegations of Fair and Responsible Lending Violations Albany, NY April 23, 2015 Legal Counsel to the Financial Services Industry Presented by Warren W. Traiger 1

2 Key Actors in Supervision and Enforcement The CFPB is authorized to enforce ECOA and HMDA. The federal prudential regulators (Fed, OCC, FDIC) enforce the CRA. Prudential regulators continue to enforce the fair lending laws (including the FHA) for depository institutions with under $10B in assets within their jurisdiction. DOJ and HUD continue to focus on enforcing fair lending laws. State regulators, including the New York Department of Financial Services and Attorney General, are also enforcing fair lending laws against institutions in their jurisdictions. 2

3 Key Actors in Supervision and Enforcement The U.S. Supreme Court currently has a critical role in shaping the future of fair lending supervision and enforcement. Poised to rule on whether facially neutral disparate impact claims are cognizable under the Fair Housing Act. Inclusive Communities Project v. Texas Dep t of Housing and Community Affairs (5th Cir., Mar. 24, 2014). 3

4 Determining Supervisory Priorities The CFPB uses a risk based prioritization process to determine which legal entities/products pose greatest risk of lending discrimination. Factors considered in prioritization determinations include: Consumer complaints Public/private litigation Information gathered from prior fair lending exams or enforcement actions Adequacy and quality of financial institution s Compliance Management System ( CMS ) Program Data analyses institution specific and horizontal Insights, information, and research from CFPB Markets teams 4

5 Developments in Supervision: NY Attorney General Redlining NY AG Settlement with Five Star Bank in which AG alleged the Bank: Intentionally excluded from its lending area the City of Rochester and predominantly minority neighborhoods in and around Rochester. Adopted lending policies that (1) automatically designated any residential mortgage secured by property outside of the bank s lending area as an undesirable loan type and (2) excluded borrowers seeking a mortgage of $75,000 or less from seven out of twelve mortgage products. Settlement terms include: Two new Rochester area branch offices. $500,000 Special Financing Program. Marketing program that will devote $250,000 to advertising directed to minority communities. Elimination of minimum mortgage amount requirement for all loan products. $150,000 in costs paid to the State of New York. New York v. Evans Bank (W.D.N.Y., Sept. 2, 2014) in which the NY AG alleges redlining in the Buffalo metro area, including: Intentionally excluding African American neighborhoods from the bank s lending area. Automatically disqualifying applicants with properties outside of the bank s trade area, which excluded all majority African American neighborhoods in Buffalo. Refusing to solicit customers, market loan products, and provide bank branches or ATMs in majority African American neighborhoods. 5

6 Developments in Supervision: DOJ, HUD and CFPB HUD Conciliation Agreement with Midlands States Bancorp (September 2014) Community group alleged that the bank excluded areas of high minority concentration from its service area and failed to market home loan products to African Americans and Hispanics. Underwriting DOJ Settlement With Fifth Third Mortgage Company (August 2014). Complaint alleged discrimination based on applicants disabilities and receipt of public assistance. The bank asked certain applicants to provide a letter from a doctor establishing the applicant s Social Security Disability Insurance income. November 2014 CFPB Bulletin: Discrimination against an applicant based upon receipt of SSDI is impermissible. Bulletin offered guidance on how to comply with ECOA when verifying SSDI. HUD Conciliation Agreements With Lenders Based on Alleged FHA Violations (July and October 2014). Alleged discrimination based on sex and/or familial status (including parental leave). Some agreements required the lender to ensure that qualified applicants on temporary leave are not required or encouraged to return to work to be approved for a mortgage. 6

7 Developments in Supervision : DOJ, HUD and CFPB Mortgage Pricing CFPB/DOJ Joint Consent Order Against National City Bank (December 2013). Complaint alleged that the bank gave loan officers and brokers discretion to set borrowers rates and fees. The bank compensated officers and brokers from extra costs paid by borrowers. Federal agencies claimed these practices resulted in African American and Hispanic borrowers paying higher prices for mortgage loans than white borrowers. Pricing and Underwriting Exceptions CFPB Spring 2014 Supervisory Highlights: When making exceptions, follow established policies and procedures, ensure exceptions are documented, and monitor/take corrective action as necessary. 7

8 Developments in Supervision: Indirect Auto Compliance Issues Increased efforts and resources devoted to development of robust CMS Consumer complaint handling Vendor oversight Targeted ECOA reviews Focus on underwriting, buy rates, and dealer markup Continued use of disparate impact analysis in all aspects of examination CFPB alleges many examinations reveal discrimination with need for corrective action Dealer markup is usually source of pricing disparities 8

9 UDAP/UDAAP Risks Claims of UDAP/UDAAP violations are steadily increasing by both CFPB and prudential regulators, including traditional banking products that have recently come under fire Recent examples of enforcement actions and examination findings Deceptive advertising of free checking accounts Unfair payment allocation methods Unfair loan servicing systems Consider conducting deep dive reviews of traditional banking deposit and loan products (checking accounts, overdraft protection, etc.), as well as loan origination and servicing systems, to determine whether any practices or processes may pose UDAP/UDAAP concerns 9

10 UDAP/UDAAP Risks Pricing If institution permits discretionary pricing, but statistical analysis results do not indicate any discriminatory pricing, may still have UDAP/UDAAP exposure based on claims of unfairness Ensure that employees exercise authority to grant pricing exceptions fairly and consistently Carefully document any pricing exceptions to mitigate both UDAP/UDAAP and fair lending risks 10

11 The CRA: Not a Fair Lending Law There is no mention of prohibited bases or protected classes in the CRA. It only addresses bank service to individuals and neighborhoods of different income levels. The CRA directs the bank regulatory agencies as follows (28 USC 2903): In connection with its examination of a financial institution, the appropriate Federal financial supervisory agency shall Assess the institution s record of meeting the credit needs of its entire community, including low and moderate income neighborhoods, consistent with the safe and sound operation of such institution; and Take such record into account in its evaluation of an application for a deposit facility by such institution. 11

12 CRA Compliance and Disparate Treatment Analysis: Part I However, the Interagency Fair Lending Examination Guidelines direct examiners to use the bank s CRA compliance record in their comparative analysis for redlining: Identify and delineate any areas within the institution s CRA assessment area and reasonably expected market area for residential products that are of a racial or national origin minority character Review prior CRA lending test analyses to learn whether they have identified any excluded or otherwise under served areas or other significant geographical disparities in the institution s lending. Determine whether any of those are minority areas. 12

13 Fair Lending Compliance Trumps CRA Performance: Part I The evaluation of a bank s CRA performance is adversely affected by evidence of discriminatory or other illegal credit practices including, but not limited to: Discrimination on a prohibited basis in violation of the Equal Credit Opportunity Act or the Fair Housing Act Violations of the Home Ownership and Equity Protection Act Violations of section 5 of the Federal Trade Commission Act Violations of section 8 of the Real Estate Settlement Procedures Act Violations of the Truth in Lending Act provisions regarding a consumer's right of rescission 13

14 Fair Lending Compliance Trumps CRA Performance: Part II The impact of discriminatory or other illegal credit practices on a bank s CRA rating depends on: The nature, extent, and strength of the evidence of the practices The policies and procedures that the institution has in place to prevent the practices Any corrective action the institution has taken, or has committed to take, including voluntary corrective action resulting from self assessment Any other relevant information, including training program Evidence of illegal credit practices generally results in a single rating downgrade, but a double downgrade is not unprecedented 14

15 The CFPB and HMDA The CFPB issued Bulletin that provides guidance on collecting and reporting HMDA data and discusses factors the CFPB may consider when deciding whether to pursue public enforcement action under HMDA. The CFPB took public enforcement actions against a bank and a non bank mortgage lender in 2013 for failure to accurately collect and report HMDA data. We are also aware of non public supervisory actions taken against banks regarding issues with their HMDA data. The CFPB issued a proposed rule to update the HMDA reporting requirements on July 24,

16 What s in the CFPB s Proposed Rule? Likely effective date: January 1, 2017 Expanded product coverage: The proposal would require the reporting of all home secured loans regardless of purpose, eliminating the categories of home purchase, refinance and home improvement. The proposal would expand HMDA coverage to mandate the reporting of open end lines of credit, home equity loans, reverse mortgages, and preapproval requests that were approved, but not accepted. 16

17 What s in the CFPB s Proposed Rule? (con t) New Data Fields: Applicant Age This will allow sorting of data by applicant age, as well as race, ethnicity and sex. Property Value Used with loan amount, this will allow calculations of the loan tovalue ratio (LTV), which measures a borrower s equity in the property and is a key underwriting and pricing factor. Credit Score Allows for a more refined fair lending statistical analysis and understanding of disparities in both underwriting and pricing outcomes. 17

18 What s in the CFPB s Proposed Rule? (con t) Loan Term Helps determine the amount of principal due with each payment, which impacts both the borrower s ability to afford the loan and the amount of interest the borrower will pay over the life of the loan. Total Points and Fees Enables deeper insight into the terms on which different communities are offered loans. Interest Rate and the Duration of Teaser or Introductory Rates Interest rate variability can be an important feature in long term affordability for borrowers. 18

19 Rationale for the Changes To improve the usefulness of HMDA data in identifying possible discriminatory lending patterns and enforcing antidiscrimination statutes: The addition of pricing data fields such as interest rate, discount points, and origination charges improves understanding of disparities in pricing outcomes beyond that permitted by the current rate spread data field. Overall, the proposed changes make fair lending analyses more comprehensive and accurate. This is especially important for the prioritization and peer analysis or redlining reviews that regulatory agencies conduct for fair lending supervision and enforcement purposes because a consistent and clean dataset will be available for all financial institutions. 19

20 Impact on Fair Lending Compliance The data to be reported under the CFPB's proposal is likely to inflame the current fair lending regulatory environment. Proposal allows regulators to analyze mortgage lending practices by applicants' age as well as by race, ethnicity and sex. Information that is currently proprietary, like applicants' credit scores and debt to income ratios and loan fees and interest rates, will now be shared annually with the CFPB and other regulators. Regulators will no longer need to wait until examination time to assess a lender s compliance with the anti discrimination laws. They will have annual access to a panoply of sensitive data from almost every mortgage lender. Agencies will be able to routinely crunch and compare data from across the industry and in any geographic area. 20

21 Impact on Fair Lending Compliance (con t) It may be only a matter of time until the enhanced data becomes public, facilitating analyses by the media and advocacy groups. The CFPB has delayed consideration of what data should be released, but its proposal states that public HMDA data [should] be modified only when the release of the unmodified data creates risks to applicant and borrower privacy interests that are not justified by the benefits of such release to the public. In other words, protecting the privacy of mortgage applicants will be the only limit on how the data is released. 21

22 How to Prepare Make sure your institution is able to accurately collect and report the new HMDA fields. Analyze your application data as if the proposed rule was in effect. Investigate any disparities in underwriting or pricing. Address any unexplained disparities. 22

23 Contact Information Warren W. Traiger Counsel

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