In comments submitted to the Consumer Financial Protection Bureau this week, NRMLA encouraged the Bureau to clarify that age-targeted advertising is not a fair lending violation under the Equal Credit Opportunity Act (ECOA) and Regulation B.
The CFPB requested comments on whether its disparate impact guidance with respect to ECOA and Reg B should be amended to provide greater clarity to lenders and consumers. NRMLA believes that greater clarity is necessary in this area, particularly because of the interplay between disparate impact, a consumer’s age and the necessities of reverse mortgage lending.
“NRMLA respectfully asserts that it is not a fair lending violation, and in fact is to consumers’ benefit, for reverse mortgage lenders to be able to target advertisements for reverse mortgage products to those consumers who are old enough to be eligible to obtain reverse mortgages,” says NRMLA in its comments.
The addition of language in Reg B recognizing that targeted advertising with respect to reverse mortgages is permissible, and that reverse mortgage products may be offered solely to consumers age 60 or older, will enhance the ability of reverse mortgage lenders to provide their products to those consumers who would most benefit from them. Read the full comments by logging into the Comment Letters section of NRMLAOnline.org.
NRMLA: Targeted Advertising Should Not Be a Fair Lending Violation
