Credit Union Exam Solutions Presents With Flying Colors

Fair Lending Basics

Oct 24, 2024

Joe Goldberg, a former NCUA official specializing in fair lending, sheds light on essential fair lending practices for credit unions. He discusses the significance of laws like the Equal Credit Opportunity Act and the Fair Housing Act, emphasizing that credit decisions should be free of discrimination. Goldberg also tackles the challenges credit unions face during NCUA examinations and explains the nuances of disparate treatment versus disparate impact. His insights provide valuable guidance for ensuring compliance and promoting equity in lending.

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Intro

00:00 • 2min

The Importance of Fair Lending

02:19 • 8min

Navigating NCUA Exams and Redlining Issues in Credit Unions

10:20 • 2min

Navigating Fair Lending in Credit Unions

12:21 • 13min

Understanding Fair Lending Laws

25:20 • 13min

Understanding Fair Lending in Credit Unions

38:30 • 2min

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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