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Fair Lending Basics with Joe Goldberg
In this episode, Mark Treichel interviews Joe Goldberg, a former NCUA official, about the basics of fair lending for credit unions. Key topics covered include:
- Definition and importance of fair lending
- Major fair lending laws: Equal Credit Opportunity Act (ECOA), Fair Housing Act, Home Mortgage Disclosure Act (HMDA)
- Types of discrimination: disparate treatment vs. disparate impact
- NCUA's fair lending examination program
- Tips for credit unions to protect themselves and ensure compliance:
- Know the laws and regulations
- Implement a robust compliance management system
- Provide adequate training
- Maintain oversight of lending practices and third parties
- Resources for credit unions to learn more about fair lending requirements
Key quotes:
"Fair lending is usually looked at by what is prohibited rather than what is required." - Joe Goldberg
"Intent is not an element of violating ECOA." - Joe Goldberg
"Credit unions try to get it right, but they don't always do that. The more they can educate themselves, the better off they will be and the better off their members will be." - Joe Goldberg
Resources mentioned:
- NCUA Fair Lending Guide
- NCUA Federal Consumer Financial Protection Guide
- FFIEC website (ffiec.gov)
- CFPB website
- NCUA regulatory alerts and letters to credit unions
