Closing SBA loans keeps doors open. Call 800.340.7304 to start www.holtandmon.com Your customers have never needed capital more than they do right now. Plus you need to offset narrowing margins by increasing noninterest fee income. SBA/USDA lending is the perfect answer. And ICBA recommends just one provider to make the process hassle-free: Holtmeyer & Monson. Give customers exactly what they need, at no net cost to your bank. Small businesses count on your expertise. You can count on ours. benefits of an act or practice may include lower prices to the consumer or a wider availability of products and services resulting from competition. A discriminatory act or practice is not shielded from the possibility of being unfair, deceptive or abusive even when fair lending laws do not apply to the conduct. For example, not allowing African-American consumers to open deposit accounts, or subjecting African-American consumers to different requirements to open deposit accounts, may be an unfair practice even in those instances when ECOA does not apply to this type of transaction. Conclusion Financial institutions directly supervised by the CFPB should treat this exam manual update as a regulation change. They should update their risk assessments, policies, procedures, processes, internal controls, audit processes, staff training, and so forth to incorporate the new application of anti-discrimination standards to areas other than credit. Financial institutions supervised by other federal agencies would be well advised to at least begin to look at this issue since the regulators tend to generally move in the same direction. William J. Showalter, CRCM, CRP is a Senior Consultant with Young & Associates, Inc. (www.younginc.com), with over 35 years experience in compliance consulting, advising and assisting financial institutions on consumer compliance and compliance management issues. He also develops and conducts compliance training programs for individual banks and their trade associations and has authored or co-authored numerous compliance publications and articles. Bill can be reached at 330-678-0524 or wshowalter@younginc.com. Continued from page 21 The natural consequence is that the overall portfolio’s yields are on the way down, and I haven’t met many people hoping for lower bond returns. 22 The Community Banker mibonline.org
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