|
|
Should a Lender Engage in Self-Testing for Discriminatory Practices?
An interagency task force released its statement on Discrimination, which says that lenders should check their actions for evidence of lending discrimination and then explains what lenders should do to fix the damage.
If a lender discovers discriminatory practices, it should make all reasonable efforts to determine the full extent of the discrimination and its cause. Were the practices grounded in defective policies? Was there poor implementation or control of those policies? Or is the problem isolated to a particular area of the lender's operations? The lender should then take all appropriate corrective actions to address the discrimination including, but not limited to, the following:
- Identify customers whose applications have been inappropriately processed, and offer to extend credit if they were improperly denied, compensating them for both out-of-pocket and compensatory damages; and notifying them of their legal rights.
- Correct any institutional policies or procedures that contributed to the discrimination.
- Identify, and then train and/or discipline, the employees involved.
Legal Issues in Collections
Translate complex legal issues into plain ENGLISH. Here's what you need to know about bankruptcies, preferences, personal and corporate guarantees, creditor's committees, security interests, reclamation letters, proofs of claims, the UCC, and much more.
Check out CollectionForum.com's
Legal Issues in Collections
|
- Consider the need for community outreach programs and/or changes in marketing strategy or loan products to better serve minority segments of the lender's market.
- Improve audit and oversight systems in order to ensure the discrimination is not repeated.
An institution is not required to report to the Agencies a lending discrimination problem it has discovered. However, a lender that reports its discovery can ensure that the corrective actions it develops are appropriate and complete and thereby minimize the damages to which it will be subject.
Editor's Note: This article originally appeared in the Credit & Collection Manager's Letter.
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
Here's what our members are saying ...
"What a great resource! This is the perfect place to refer our customers who have collection problems so they can improve their collections.
I figure if we can help them collect faster, they can pay us faster and order more product."
William C. Edgar, CCE
Director of Credit
Zippo Manufacturing
"I can't believe I didn't find out about your site sooner."
"It was exactly what I was looking for."
Jim P.
Hot Springs, AR
"The first item I found in your download library made my subscription worthwhile. I'm definitely renewing!"
John A.
Kerrville, TX
"Your site saved the day for me. The video tutorial helped me quickly and solve a problem I've been struggling with for a year.
Robert K.
London, UK
"I can't say enough about how valuable your site has been to our business. The articles and especially the free downloads really are great."
Victor O.
Seattle, WA
|
|
|
|
|
|
|