By: Steve Shepherd, CRCM,
On May 6, 2020 the CFPB (Consumer Financial Protection Bureau) issued a compliance aid with respect to compliance with Regulation B ECOA’s notice of action taken rules and the SBA’s (Small Business Administration) Paycheck Protection Program.
The new compliance aid comes in the form of three questions and answers from the CFPB regarding a completed application and the financial institution’s responsibilities for applications taken under the SBA’s Paycheck Protection Program.
A few of the interesting areas to note are that 1) an institution does not have a completed application sufficient to issue an action taken until it has been issued a loan number by the SBA and 2) if the institution refuses to grant credit prior to receiving an SBA loan number, the financial institution has made a credit decision and a notice of action taken would be required.
For additional information regarding the Regulation B ECOA requirements and the Paycheck Protection Program please see the compliance aid and additional guidance the CFPB has provided located at:
https://files.consumerfinance.gov/f/documents/cfpb_ecoa-regulation-b_faqs-covid-19.pdf
On May 6, 2020 the CFPB (Consumer Financial Protection Bureau) issued a compliance aid with respect to compliance with Regulation B ECOA’s notice of action taken rules and the SBA’s (Small Business Administration) Paycheck Protection Program.
The new compliance aid comes in the form of three questions and answers from the CFPB regarding a completed application and the financial institution’s responsibilities for applications taken under the SBA’s Paycheck Protection Program.
A few of the interesting areas to note are that 1) an institution does not have a completed application sufficient to issue an action taken until it has been issued a loan number by the SBA and 2) if the institution refuses to grant credit prior to receiving an SBA loan number, the financial institution has made a credit decision and a notice of action taken would be required.
For additional information regarding the Regulation B ECOA requirements and the Paycheck Protection Program please see the compliance aid and additional guidance the CFPB has provided located at:
https://files.consumerfinance.gov/f/documents/cfpb_ecoa-regulation-b_faqs-covid-19.pdf
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