Alert July 23, 2013

CFPB Releases ECOA Baseline Review Examination Procedures

The CFPB published its baseline review modules for examination of compliance with the Equal Credit Opportunity Act. The modules will be used by examiners during ECOA baseline reviews to identify and analyze risks of ECOA violations and to inform fair lending prioritization decisions for future CFPB reviews, among other uses. The examination procedures contain the following six modules, which may be used in various combinations during examinations: (1) fair lending supervisory history; (2) fair lending compliance management system; (3) risks related to mortgage lending policies and procedures; (4) risks related to mortgage servicing; (5) risks related to auto lending and (6) risks related to other products.