Compliance Blog

There is a good deal of "internet chatter" about possible Reg B violations concerning credit reports.  Reportedly, FDIC examiners are looking at how banks pull credit reports.  Specifically, are these banks treating married joint applicants and non-married joint applicants differently?  Reportedly, credit bureaus allow creditors to pull a "joint" credit report in certain situations, which is less than the cost of pulling two single reports.  Creditors who choose to pull a joint report for married applicants, but who pull two separate single reports for non-married joint applicants may be seen as discriminating on marital status if they pass the costs on to the borrowers.. 

The FDIC has not issued any official guidance on this, and you won't find anything inside Reg B rules or commentary. Here's one thread from Banker's Online that talks about this issue.  Here's another posting from the Bankers Advisory Blog.  In addition, it is worth noting that this chatter seems to surround the FDIC. NCUA would enforce Reg B for FCUs, with the FTC enforcing it for state chartered credit unions.

I'll keep an eye on this to see if any official guidance comes out. 

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Have a great weekend, everyone.  Even you Phillies fans.  After two games against the N.L. Champs, it is clear that the Nationals have a way to go.  Luckily, Penn State's Blue White game is only a few weeks away.  I'm guaranteed a win in that one.