The CFPB recently released its annual Fair Lending Report (Report) that highlights its “new fair lending priorities” and the need to correct previous “regulatory overreach”. The Report recaps actions taken by the CFPB to align with different Executive Orders, including actions related to disparate impact, debanking, etc., and it provides insight into some frequently cited Regulation B violations.
A few of the common violations noted include:
Limitation on signatures - §1002.7(d)(1)
Institutions required the signature of an individual applicant’s spouse or other individual without first determining whether or not the applicant qualified for individual credit.
Notification requirements for Adverse Action/Incomplete Applications - §1002.9
Adverse action notice issues are certainly nothing new, but there were some new issues included this time around. These included:
- Failing to provide the ECOA Notice along with the name and address of the creditor’s federal regulator;
- Failing to provide a notice of incompleteness when additional information was needed from the applicant; and,
- Failing to provide timely notice to business applicants.
Training is available now OnDemand for many of the topics raised in this Report. Some must-haves include:
Additionally, be sure to register for “Debanking – The Order & The Expectations” which is coming up on December 8th.
Published 2026/10/28
