Tag: ECOA

5 articles tagged “ECOA”

How Long the Agent's Evidence Has to Live: Retention Clocks for AI Mortgage Records Under Reg B, Reg Z, and Reg C, and the Default That Deletes Your Proof

An AI agent produces the record that proves a decision was compliant, and that record is worthless if the infrastructure deletes it before the exam or the lawsuit arrives. The 25-month ECOA clock, the three- and five-year TRID clocks, the HMDA retention period, and why retention has to be keyed to the loan event rather than a storage default that outlives nothing.

Sep 18, 20269 min read

The Appraisal-Copy Rule Runs on Its Own Clock: Delivering Valuations Under ECOA 1002.14 With an AI Agent, Even When the Loan Is Denied

Regulation B 1002.14 makes a lender deliver every appraisal and written valuation to the applicant promptly upon completion, and the duty survives a denial or withdrawal. How an AI origination agent tracks valuation-completion events, delivers to the primary applicant, captures a valid waiver, and keeps the free-copy rule from turning into a fee complaint.

Sep 4, 20266 min read

CFPB 1071 Small Business Lending and AI Agents: A Subpart B Playbook for the Firewall, the Data, and the Filing

Section 1071 added 81 data points and a firewall between demographic collection and credit decisions. How to put AI agents inside the small-business application without breaching Regulation B Subpart B.

May 29, 20265 min read

Fair Lending Testing for AI Agents: A Disparate Impact Playbook Under ECOA, HMDA, and the FHA

A working method for fair-lending testing of AI agents used in origination, marketing, and servicing — covering disparate impact, less-discriminatory-alternative search, marketing steering, and the exam-ready file.

May 15, 20266 min read

Adverse Action Notices for AI Credit Decisions: An ECOA Reg B Playbook

What CFPB Circular 2023-03 means for lenders running AI/ML credit models — how to generate specific, accurate reasons for denial under ECOA Regulation B without falling back on the sample form checklist.

May 10, 20264 min read

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