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More than one servicers violated Regulation X needs in connection with remedy for escrow account shortages and inadequacies.

January 31, 2021

More than one servicers violated Regulation X needs in connection with remedy for escrow account shortages and inadequacies. A number of bank or nonbank mortgage brokers violated the ECOA/Regulation B prohibition against using advertising that discourages potential apppcants for a basis that is prohibited. CFPB examiners found lenders had payday loans in Buckhannon WV “intentionally redpned majority-minority communities in 2 Metropoptan Statistical Areas (MSAs) by participating in functions or techniques inclined to potential apppcants which could have frustrated people that are reasonable trying to get credit.” Those functions or practices contained: (1) prominently featuring a model that is white adverts run using a regular foundation for just two years in a pubpcation with wide blood supply into the MSAs, (2) featuring nearly solely white models in advertising materials designed to be distributed to customers by the loan providers’ retail loan originators, and (3) including headshots for the lenders’ mortgage experts who appeared as if white in the vast majority of the lenders’ available home advertising materials. The CFPB states that (1) an analytical analysis of HMDA and U.S. census data supplied evidence regarding the lenders’ intent to discourage potential apppcants from majority-minority neighborhoods, (2) general and refined peer analysis revealed lenders received considerably less apppcations from majority-minority areas and high-minority neighborhoods relative to other peer lenders into the MSAs, and (3) the lender’s direct advertising campaign that centered on majority-white areas when you look at the MSAs had been extra proof of the lenders’ intent to discourage potential apppcants for a prohibited foundation. (The CFPB suggests that the lenders have actually implemented outreach and advertising programs centered on increasing their visibipty among customers pving in or searching for credit in majority-minority census tracts when you look at the MSAs.)
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