ECOA Compliance Sample Clauses
ECOA Compliance. If Licensee has determined that it is required by the Equal Credit Opportunity Act (ECOA) to provide a Customer a copy of certain property valuation information Licensee has obtained using the Licensed Application, Licensee must provide the Customer a document (the “Valuation Disclosure”) that contains the following information extracted from the SMDU response file: the standardized address, predicted value, confidence score and response date/timestamp. The Valuation Disclosure must also include the following language:
ECOA Compliance. A. The form of Adverse Action Notice used by FFG must be modified to comply with federal laws 12 CFR §202.9(b). The Federal Equal Credit Opportunity Act (“ECOA”) notice located at the bottom of the Adverse Action Notice form must be amended as follows: Add the words “sex, marital status” after the words “national origin”.
B. FFG needs to discontinue its policy of not combining income of non-married co-applicants. This practice likely violates the ECOA prohibition against credit discrimination based upon marital status. Markham v. Colonial Mortg. Service Co. 605 F.2d (D.C. Cir. 1979). FFG should revise its Frequently Asked Questions on its website to either (i) delete loan combination question in the context of non-married co-applicants; or (ii) revise the answer to the question: Do you combine income for girlfriend/boyfriend or fiancé type of deals? as follows: “Yes, we combine income for non-married co-applicants.”