Letter to credit unions 22-CU-04

by David Park, NAFCU Compliance Blog

Earlier this week, the National Credit Union Administration (NCUA) issued a letter to credit unions, 22-CU-04, about the Equal Credit Opportunity Act (ECOA). The letter reminded federally insured credit unions that ECOA prohibits credit unions from discriminating against credit applicants because of a prohibited basis (e.g., “race, color, religion, national origin, sex, marital status, or age (provided the applicant has the capacity to contract); . . . the fact that all or part of the applicant’s income derives from a public assistance program; or . . . the fact that the applicant has in good faith exercised any right under the Consumer Credit Protection Act”). Under ECOA and Regulation B, the prohibition extends to “any aspect of a credit transaction.”

The letter identified several practices that would be prohibited by ECOA, including the following:

  • Failing to give the same information about the application process or underwriting standards to different applicants because of a prohibited basis;
  • Discouraging certain applicants from asking about or applying for credit because of a prohibited basis;

 

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