WASHINGTON–Following a move by the CFPB to finalize and update the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Reg B, in April, America’s Credit Unions has published new Final Rule Summary to analyze its effect on credit unions.
As the trade group noted, specifically it amends provisions related to disparate impact, discouragement of applicants or prospective applicants, and conditions under which a creditor may offer special-purpose credit programs under Regulation B.
Abut the Rule
America’s Credit Unions said the rule is effective starting July 21 and:
- Removes disparate-impact (effects-test) language from Regulation B;
- Narrows the discouragement provision to “oral or written statements;”
- Clarifies that discouragement covers only statements directed at applicants or prospective applicants;
- Clarifies that the notion encouraging one group does not, by itself, constitute discouragement of non-recipient; and
- Revises the discouragement knowledge standard so that a violation occurs only when a creditor knows a statement would communicate discriminatory outcomes.
America’s Credit Unions’ analysis and final rule summaries can be found here.
