On January 6, 2022, the CFPB issued its Fall 2021 Supervisory Highlights, available here. Of interest to residential mortgage lenders is the CFPB’s description of its fair lending examination results. It found that lenders may have violated ECOA by failing to make pricing exceptions in response to competitive offers from other lenders where the applicants were African American or female. Examiners observed that lenders generally maintained policies and procedures for pricing exceptions, including exceptions to competitive offers, but that managers often required consumers to request the exception, and often did not document the reason for the exception. In response to these findings, lenders were asked to undertake remedial and corrective action with respect to their policies and procedures.
In this blog post concerning legal and regulatory matters of interest to the mortgage industry, Sandler Law Group (SLG) provides general information and industry observations that are not motivated by or concerned with a particular past occurrence or event, or a specific existing legal problem of which SLG is aware. Nothing published herein is intended to constitute legal advice and the use of the newsletter by a reader shall not give rise to an attorney-client relationship with SLG. SLG expressly disclaims any representation of accuracy or reliability as to the content of this newsletter, as well as any obligation to maintain such content over time or to ensure it is free from errors. Brad Cope is the attorney responsible for the SLG content of this newsletter. The attorneys of SLG are not certified by the Texas Board of Legal Specialization, except as otherwise noted at www.sandlerllc.com.
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