source:
  type: regulation
  id: reg-b-1002-supplement-i
  authority: "Supplement I to 12 CFR Part 1002 \u2014 Official Bureau Interpretations (Regulation B Commentary)"
  description: 'Supplement I to 12 CFR Part 1002 is the CFPB''s official staff

    commentary on Regulation B (ECOA). Each commentary obligation

    interprets a specific Reg B rule obligation via the `interprets`

    field.

    '
obligations:
- id: reg-b-1002-supp-i-5a2-loan-broker-collection
  canonical_id: reg-b-1002-supp-i-5a2-loan-broker-collection
  section: "Supplement I \u2014 Comment 5(a)(2)-3: Collecting information on behalf of creditors"
  description: "The Bureau interprets \xA71002.5(a)(2) such that persons such as loan\nbrokers and correspondents do not violate ECOA or Reg B\
    \ if they\ncollect information they are otherwise prohibited from collecting,\nwhere the purpose is to provide it to a creditor subject to\
    \ subpart\nB of this part, the Home Mortgage Disclosure Act, or another\nFederal/state statute or regulation requiring data collection.\n"
  interprets: reg-b-1002.5-a2-required-monitoring-info
  type: do
  audit_question: If [LENDER] operates as a loan broker or correspondent collecting monitoring information on behalf of an upstream creditor subject
    to subpart B of Reg B, HMDA, or another data-collection statute, is that collection workflow documented and limited to permissible purposes,
    per Comment 5(a)(2)-3?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - broker-correspondent
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 5(a)(2)-3"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: 3. Collecting information on behalf of creditors. Persons such as loan brokers and correspondents do not violate the ECOA
      or Regulation B if they collect information that they are otherwise prohibited from collecting, where the purpose of collecting the information
      is to provide it to a creditor that is subject to subpart B of this part, the Home Mortgage Disclosure Act, or another Federal or State
      statute or regulation requiring data collection.
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 5(a)(2)-3.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: If [LENDER] acts as a loan broker/correspondent collecting monitoring information on behalf of an upstream creditor (subpart
    B), HMDA, or another data-collection statute, does the program account for that role by documenting the collection workflow and limiting it
    to the permissible on-behalf-of purpose under Comment 5(a)(2)-3?
  file_review: Spot-check broker/correspondent files; confirm the collection is documented and tied to a permissible upstream-creditor / HMDA
    / statutory purpose.
  judgment: false
- id: reg-b-1002-supp-i-5d1-indirect-marital-disclosure
  canonical_id: reg-b-1002-supp-i-5d1-indirect-marital-disclosure
  section: "Supplement I \u2014 Comment 5(d)(1)-1: Indirect disclosure of marital status"
  description: "The Bureau interprets \xA71002.5(d)(1) such that the fact that certain\ncredit-related information may indirectly disclose marital\
    \ status\ndoes not bar [LENDER] from seeking such information \u2014 for example,\nasking about obligation to pay alimony/child support/separate\n\
    maintenance, the source of income to be used as repayment basis,\nwhether disclosed obligations have co-obligors, or ownership of\nassets.\n"
  interprets: reg-b-1002.5-d1-marital-status-inquiry-limit
  type: do
  audit_question: "When [LENDER]'s application asks about repayment-related items that may incidentally reveal marital status (alimony obligation,\
    \ income source, co-obligors, joint asset ownership), does the form lean on Comment 5(d)(1)-1 rather than the \xA71002.5(d)(1) marital-status\
    \ inquiry restriction?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - marital-status
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 5(d)(1)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: '1. Indirect disclosure of prohibited information. The fact that certain credit-related information may indirectly disclose
      marital status does not bar a creditor from seeking such information. For example, the creditor may ask about:'
    drafter_attestation: "Copied verbatim from snapshot 10df644d0120766e (content.txt) at\n2026-05-22T19:00Z. Substring is the Comment 5(d)(1)-1\
      \ headline;\nthe (i)\u2013(iv) examples are paraphrased in description.\n"
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the indirect-disclosure allowance \u2014 so that repayment-related inquiries (alimony/child-support\
    \ obligations, income source, co-obligors, joint asset ownership) that may incidentally reveal marital status are permitted under Comment\
    \ 5(d)(1)-1 rather than blocked by the \xA71002.5(d)(1) marital-status restriction?"
  file_review: Review the application form; confirm any inquiries that touch marital status indirectly are repayment-related items the comment
    permits, not a general marital-status inquiry.
  judgment: false
- id: reg-b-1002-supp-i-5d2-specific-income-inquiry
  canonical_id: reg-b-1002-supp-i-5d2-specific-income-inquiry
  section: "Supplement I \u2014 Comment 5(d)(2)-3: Specific inquiry about sources of income"
  description: "The Bureau interprets \xA71002.5(d)(2) such that [LENDER] need not give\nthe alimony/child-support/separate-maintenance disclosure\
    \ if the\ninquiry about income is specific and worded in a way that is\nunlikely to lead the applicant to disclose that the income is\nderived\
    \ from such payments. For example, an application form that\nasks about specific types of income such as salary, wages, or\ninvestment income\
    \ need not include the disclosure.\n"
  interprets: reg-b-1002.5-d2-alimony-disclosure
  type: do
  audit_question: For [LENDER] application forms that elicit income by specific category (salary, wages, investment income) rather than by general
    source inquiry, can [LENDER] evidence that the alimony/child-support/separate-maintenance disclosure is omitted in reliance on Comment 5(d)(2)-3?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - alimony-disclosure
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 5(d)(2)-3"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: 3. Specific inquiry about sources of income. A creditor need not give the disclosure if the inquiry about income is specific
      and worded in a way that is unlikely to lead the applicant to disclose the fact that income is derived from alimony, child support, or separate
      maintenance payments. For example, an application form that asks about specific types of income such as salary, wages, or investment income
      need not include the disclosure.
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 5(d)(2)-3.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the specific-income-category carve-out \u2014 so that when the form asks for income by specific\
    \ category (salary, wages, investment income) unlikely to elicit alimony/child-support/separate-maintenance, the \xA71002.5(d)(2) disclosure\
    \ may be omitted in reliance on Comment 5(d)(2)-3?"
  file_review: Review the income section of the live form; confirm that where the disclosure is omitted, the income inquiry is specific-category
    and not a general-source inquiry.
  judgment: false
- id: reg-b-1002-supp-i-6a-effects-test
  canonical_id: reg-b-1002-supp-i-6a-effects-test
  section: "Supplement I \u2014 Comment 6(a)-2: Effects test"
  description: "The Bureau interprets \xA71002.6(a) such that the effects test is a\njudicial doctrine from Title VII employment cases; ECOA and\
    \ Reg B\nmay prohibit a creditor practice that is discriminatory in effect\nbecause it has a disproportionately negative impact on a prohibited\n\
    basis, even though [LENDER] has no intent to discriminate and the\npractice appears neutral on its face \u2014 unless the practice meets a\n\
    legitimate business need that cannot reasonably be achieved as well\nby less-disparate means.\n"
  interprets: reg-b-1002.6-a-effects-test-general-rule
  type: do
  audit_question: When [LENDER] adopts a facially-neutral credit-policy practice (e.g., minimum income threshold), can [LENDER] articulate the
    legitimate business need served and demonstrate why no less-disparate alternative reasonably achieves it, per Comment 6(a)-2?
  workflow_phase: underwriting
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: annual
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - underwriting
  - effects-test
  - disparate-impact
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 6(a)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: 2. Effects test. The effects test is a judicial doctrine that was developed in a series of employment cases decided by the
      U.S. Supreme Court under title VII of the Civil Rights Act of 1964 ( 42 U.S.C. 2000e et seq., ) and the burdens of proof for such employment
      cases were codified by Congress in the Civil Rights Act of 1991 ( 42 U.S.C. 2000e-2 ). Congressional intent that this doctrine apply to
      the credit area is documented in the Senate Report that accompanied H.R. 6516, No. 94-589, pp. 4-5; and in the House Report that accompanied
      H.R. 6516, No. 94-210, p.5. The Act and regulation may prohibit a creditor practice that is discriminatory in effect because it has a disproportionately
      negative impact on a prohibited basis, even though the creditor has no intent to discriminate and the practice appears neutral on its face,
      unless the creditor practice meets a legitimate business need that cannot reasonably be achieved as well by means that are less disparate
      in their impact.
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the Comment 6(a)-2 headline and

      operative paragraph (through "less disparate in their impact"); the

      worked overdraft example that follows is omitted (the verifier

      checks substring, not full-comment inclusion).

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program facilitate effects-test analysis of facially-neutral credit practices \u2014 so that for any neutral practice\
    \ with disproportionate prohibited-basis impact, [LENDER] can articulate the legitimate business need and show no less-disparate alternative\
    \ reasonably achieves it (Comment 6(a)-2)?"
  file_review: Review the business-justification documentation for flagged neutral practices; the compliance person judges whether the legitimate
    business need is made out and whether a less-disparate alternative was reasonably available.
  judgment: true
- id: reg-b-1002-supp-i-6b2-elderly-favor
  canonical_id: reg-b-1002-supp-i-6b2-elderly-favor
  section: "Supplement I \u2014 Comment 6(b)(2)-1: Favoring the elderly"
  description: "The Bureau interprets \xA71002.6(b)(2) such that any system of\nevaluating creditworthiness may favor a credit applicant who is\n\
    age 62 or older. A credit program offering more favorable credit\nterms to applicants 62 or older is permissible; a program that\noffers more\
    \ favorable terms to applicants at an age lower than 62\nis permissible only if it meets the \xA71002.8 special-purpose-credit\nrequirements.\n"
  interprets: reg-b-1002.6-b2-age-public-assistance
  type: do
  audit_question: "If [LENDER] operates a credit program that offers more favorable terms to applicants below age 62, can [LENDER] evidence that\
    \ the program meets \xA71002.8 special-purpose-credit requirements, per Comment 6(b)(2)-1?"
  workflow_phase: underwriting
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: annual
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - underwriting
  - elderly
  - special-purpose-credit
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 6(b)(2)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "1. Favoring the elderly. Any system of evaluating creditworthiness may favor a credit applicant who is age 62 or older.\
      \ A credit program that offers more favorable credit terms to applicants age 62 or older is also permissible; a program that offers more\
      \ favorable credit terms to applicants at an age lower than 62 is permissible only if it meets the special-purpose credit requirements of\
      \ \xA7 1002.8 ."
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 6(b)(2)-1.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the age-favoring rule \u2014 favoring applicants 62+ is permissible, but a program offering more\
    \ favorable terms to applicants below 62 is permissible only if it meets \xA71002.8 special-purpose-credit requirements?"
  file_review: "Spot-check any age-favorable program; if the favorable age threshold is below 62, confirm \xA71002.8 special-purpose-credit qualification\
    \ is documented."
  judgment: false
- id: reg-b-1002-supp-i-6b2-age-credit-scoring
  canonical_id: reg-b-1002-supp-i-6b2-age-credit-scoring
  section: "Supplement I \u2014 Comment 6(b)(2)-2: Age in credit scoring (elderly-favorable treatment)"
  description: "The Bureau interprets \xA71002.6(b)(2) such that age may be taken\ndirectly into account in a credit-scoring system that is\n\"\
    demonstrably and statistically sound\" (per \xA71002.2(p)), with one\nlimitation: applicants age 62 or older must be treated at least as\n\
    favorably as applicants under 62. If age is scored by assigning\npoints to age categories, elderly applicants must receive the same\nor a\
    \ greater number of points as the most-favored class of\nnonelderly applicants.\n"
  interprets: reg-b-1002.6-b2-age-public-assistance
  type: do
  audit_question: If [LENDER] uses a credit-scoring system that scores age, does the system documentation evidence that applicants 62+ receive
    at least as many points as the most-favored nonelderly class, per Comment 6(b)(2)-2?
  workflow_phase: underwriting
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: annual
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - underwriting
  - credit-scoring
  - age
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 6(b)(2)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "2. Consideration of age in a credit scoring system. Age may be taken directly into account in a credit scoring system that\
      \ is \u201Cdemonstrably and statistically sound,\u201D as defined in \xA7 1002.2(p) , with one limitation: Applicants age 62 years or older\
      \ must be treated at least as favorably as applicants who are under age 62. If age is scored by assigning points to an applicant's age category,\
      \ elderly applicants must receive the same or a greater number of points as the most favored class of nonelderly applicants."
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 6(b)(2)-2.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for scored age \u2014 so that any demonstrably-and-statistically-sound system that scores age guarantees\
    \ applicants 62+ receive at least as many points as the most-favored nonelderly class (Comment 6(b)(2)-2)?"
  file_review: Review the scoring-system documentation; confirm the elderly-at-least-as-favorable point allocation holds for the 62+ category.
  judgment: false
- id: reg-b-1002-supp-i-6b5-payments-consistently-made
  canonical_id: reg-b-1002-supp-i-6b5-payments-consistently-made
  section: "Supplement I \u2014 Comment 6(b)(5)-2: Payments consistently made (alimony/child support)"
  description: "The Bureau interprets \xA71002.6(b)(5) such that in determining the\nlikelihood of consistent payments of alimony, child support,\
    \ or\nseparate maintenance, [LENDER] may consider factors such as whether\npayments are received pursuant to a written agreement or court\n\
    decree; the length of time payments have been received; whether\npayments are regularly received; the availability of court or other\nprocedures\
    \ to compel payment; and the creditworthiness of the\npayor, including the payor's credit history when available.\n"
  interprets: reg-b-1002.6-b5-income-rule
  type: do
  audit_question: When [LENDER] evaluates alimony/child-support/separate-maintenance income for continuance/consistency, does the analysis consider
    the Comment 6(b)(5)-2 factors (written agreement/decree, payment history length and regularity, enforcement procedures, payor creditworthiness)?
  workflow_phase: underwriting
  owner_role: underwriter
  secondary_owner_role: compliance_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - underwriting
  - income
  - alimony
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 6(b)(5)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: 2. Payments consistently made. In determining the likelihood of consistent payments of alimony, child support, or separate
      maintenance, a creditor may consider factors such as whether payments are received pursuant to a written agreement or court decree; the
      length of time that the payments have been received; whether the payments are regularly received by the applicant; the availability of court
      or other procedures to compel payment; and the creditworthiness of the payor, including the credit history of the payor when it is available
      to the creditor.
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 6(b)(5)-2.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program facilitate a consistency analysis for alimony/child-support/separate-maintenance income that weighs the Comment\
    \ 6(b)(5)-2 factors \u2014 written agreement or decree, length and regularity of receipt, availability of enforcement procedures, and payor\
    \ creditworthiness?"
  file_review: Pull files relying on such income; the compliance person judges whether the likely-consistent-continuance determination reasonably
    weighed the relevant factors.
  judgment: true
- id: reg-b-1002-supp-i-7d1-signature-of-another-person
  canonical_id: reg-b-1002-supp-i-7d1-signature-of-another-person
  section: "Supplement I \u2014 Comment 7(d)(1)-1: Signature of another person (impermissible cosigner requirement)"
  description: "The Bureau interprets \xA71002.7(d)(1) such that it is impermissible\nfor [LENDER] to require an applicant who is individually\n\
    creditworthy to provide a cosigner \u2014 even if [LENDER] applies the\nrequirement without regard to sex, marital status, or any other\n\
    prohibited basis. (Closely-held-corporation guarantor practice is\nseparately addressed in Comment 7(d)(6)-1.)\n"
  interprets: reg-b-1002.7-d1-no-spousal-signature
  type: dont
  audit_question: For every individually-creditworthy [LENDER] applicant, can [LENDER] evidence that no cosigner was required (regardless of whether
    the requirement would have been applied without prohibited-basis distinction), per Comment 7(d)(1)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - cosigner
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 7(d)(1)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "1. Signature of another person. It is impermissible for a creditor to require an applicant who is individually creditworthy\
      \ to provide a cosigner\u2014even if the creditor applies the requirement without regard to sex, marital status, or any other prohibited\
      \ basis. (But see comment 7(d)(6)-1 concerning guarantors of closely held corporations.)"
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 7(d)(1)-1.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program make it hard to require a cosigner from an individually-creditworthy applicant \u2014 even where the cosigner\
    \ requirement would be applied without prohibited-basis distinction (Comment 7(d)(1)-1)?"
  file_review: Pull files where a cosigner was added; the compliance person judges whether the applicant already qualified individually, in which
    case the cosigner requirement was impermissible.
  judgment: true
- id: reg-b-1002-supp-i-7d2-jointly-owned-property
  canonical_id: reg-b-1002-supp-i-7d2-jointly-owned-property
  section: "Supplement I \u2014 Comment 7(d)(2)-1: Jointly owned property valuation"
  description: "The Bureau interprets \xA71002.7(d)(2) such that if an applicant\nrequests unsecured credit, does not own sufficient separate\n\
    property, and relies on joint property to establish creditworthiness,\n[LENDER] must value the applicant's interest in the jointly owned\n\
    property. [LENDER] may not request that a nonapplicant joint owner\nsign any instrument as a condition of the credit extension unless\nthe\
    \ applicant's interest does not support the amount and terms of\nthe credit sought.\n"
  interprets: reg-b-1002.7-d1-no-spousal-signature
  type: dont
  audit_question: For every unsecured-credit application where the applicant relies on joint property, can [LENDER] evidence that the applicant's
    individual interest in the joint property was valued first, and that a nonapplicant joint-owner signature was required only where the applicant's
    interest does not support the amount/terms, per Comment 7(d)(2)-1?
  workflow_phase: underwriting
  owner_role: underwriter
  secondary_owner_role: compliance_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - underwriting
  - joint-property
  - spousal-signature
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 7(d)(2)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: 1. Jointly owned property. If an applicant requests unsecured credit, does not own sufficient separate property, and relies
      on joint property to establish creditworthiness, the creditor must value the applicant's interest in the jointly owned property. A creditor
      may not request that a nonapplicant joint owner sign any instrument as a condition of the credit extension unless the applicant's interest
      does not support the amount and terms of the credit sought.
    drafter_attestation: "Copied verbatim from snapshot 10df644d0120766e (content.txt) at\n2026-05-22T19:00Z. Substring is the Comment 7(d)(2)-1\
      \ headline\noperative paragraph; the (i)\u2013(ii) valuation-detail sub-items are\nparaphrased in description.\n"
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for unsecured-credit applicants relying on joint property \u2014 so that [LENDER] values the applicant's\
    \ individual interest first, and a nonapplicant joint-owner signature is required only where that interest does not support the amount/terms\
    \ (Comment 7(d)(2)-1)?"
  file_review: Pull unsecured-credit files relying on joint property; confirm the applicant's interest was valued, and where a joint-owner signature
    was required, that it was because the interest did not support the credit sought.
  judgment: false
- id: reg-b-1002-supp-i-7d4-secured-credit-lien
  canonical_id: reg-b-1002-supp-i-7d4-secured-credit-lien
  section: "Supplement I \u2014 Comment 7(d)(4)-1: Creation of enforceable lien (note-vs-security distinction)"
  description: "The Bureau interprets \xA71002.7(d)(4) such that if an applicant\noffers real property as security for credit and state law requires\n\
    both spouses to join in executing the encumbering instrument,\n[LENDER] may require the applicant's spouse to sign the instruments\nnecessary\
    \ to create a valid security interest. However, [LENDER]\nmay not require the spouse to sign the note evidencing the credit\nobligation if\
    \ signing only the mortgage or other security agreement\nis sufficient \u2014 unless state law requires both spouses to sign the\nnote to\
    \ create an enforceable lien.\n"
  interprets: reg-b-1002.7-d4-secured-credit-spousal-signature
  type: dont
  audit_question: For every secured-credit transaction where [LENDER] requires a spouse's signature on a security instrument, does the file evidence
    (i) which state-law requirement compels the spouse's signature, and (ii) that the spouse is asked to sign the note ONLY where state law requires
    it for an enforceable lien, per Comment 7(d)(4)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - spousal-signature
  - secured-credit
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 7(d)(4)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: 1. Creation of enforceable lien. Some state laws require that both spouses join in executing any instrument by which real
      property is encumbered. If an applicant offers such property as security for credit, a creditor may require the applicant's spouse to sign
      the instruments necessary to create a valid security interest in the property. The creditor may not require the spouse to sign the note
      evidencing the credit obligation if signing only the mortgage or other security agreement is sufficient to make the property available to
      satisfy the debt in the event of default. However, if under state law both spouses must sign the note to create an enforceable lien, the
      creditor may require the signatures.
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 7(d)(4)-1.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the note-vs-security-instrument distinction in secured credit \u2014 so that a spouse is asked\
    \ to sign only the instruments needed to create a valid security interest, and is asked to sign the NOTE only where state law requires both\
    \ spouses to sign the note for an enforceable lien (Comment 7(d)(4)-1)?"
  file_review: Pull secured-credit files with a spousal signature; confirm (i) the state-law basis for the signature and (ii) that any spousal
    note signature is tied to a state-law enforceable-lien requirement, not bundled by default.
  judgment: false
- id: reg-b-1002-supp-i-9-prequalification-as-application
  canonical_id: reg-b-1002-supp-i-9-prequalification-as-application
  section: "Supplement I \u2014 Comment 9-5: Prequalification requests as applications subject to adverse-action notice"
  description: "The Bureau interprets \xA71002.9 such that whether [LENDER] must\nprovide a notice of action taken for a prequalification request\n\
    depends on [LENDER]'s response. [LENDER] may treat the request as\nan inquiry if it evaluates specific information and tells the\nconsumer\
    \ the loan amount/rate/terms they could qualify for under\nvarious programs, explaining the process to submit an application.\nOn the other\
    \ hand, [LENDER] has treated the request as an\napplication \u2014 and is subject to \xA71002.9 adverse-action requirements\n\u2014 if, after\
    \ evaluating information, [LENDER] decides it will not\napprove the request and communicates that decision to the consumer.\n"
  interprets: reg-b-1002.9-a1-30-day-notification
  type: do
  audit_question: "When [LENDER] decides not to approve a prequalification request and communicates that decision to the consumer (e.g., \"we\
    \ could not approve a mortgage because of a bankruptcy in your record\"), does [LENDER] treat the request as an application subject to \xA7\
    1002.9 adverse-action notice, per Comment 9-5?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-prequalification
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - prequalification
  - adverse-action
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 9-5"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "5. Prequalification requests. Whether a creditor must provide a notice of action taken for a prequalification request depends\
      \ on the creditor's response to the request, as discussed in comment 2(f)-3. For instance, a creditor may treat the request as an inquiry\
      \ if the creditor evaluates specific information about the consumer and tells the consumer the loan amount, rate, and other terms of credit\
      \ the consumer could qualify for under various loan programs, explaining the process the consumer must follow to submit a mortgage application\
      \ and the information the creditor will analyze in reaching a credit decision. On the other hand, a creditor has treated a request as an\
      \ application, and is subject to the adverse action notice requirements of \xA7 1002.9 if, after evaluating information, the creditor decides\
      \ that it will not approve the request and communicates that decision to the consumer. For example, if the creditor tells the consumer that\
      \ it would not approve an application for a mortgage because of a bankruptcy in the consumer's record, the creditor has denied an application\
      \ for credit."
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 9-5.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the prequalification fork \u2014 so that when [LENDER] evaluates information, decides it will\
    \ NOT approve, and communicates that decision, the request is treated as a denied application triggering the \xA71002.9 adverse-action notice\
    \ (and not as a mere inquiry)?"
  file_review: "Spot-check prequalification records where the consumer was told they could not qualify; confirm those were treated as applications\
    \ and got \xA71002.9 notices, while true inquiries (told what they could qualify for) were not."
  judgment: false
  feeds:
  - reg-b-1002.9-a1-30-day-notification
- id: reg-b-1002-supp-i-9a1-application-complete
  canonical_id: reg-b-1002-supp-i-9a1-application-complete
  section: "Supplement I \u2014 Comment 9(a)(1)-1: Timing of notice \u2014 when an application is complete"
  description: "The Bureau interprets \xA71002.9(a)(1) such that once [LENDER] has\nobtained all the information it normally considers in making\
    \ a\ncredit decision, the application is complete and [LENDER] has 30\ndays in which to notify the applicant of the credit decision.\n"
  interprets: reg-b-1002.9-a1-30-day-notification
  type: do
  audit_question: Does [LENDER]'s application-tracking system mark "completeness" at the point all normally-considered information is obtained,
    and then enforce a 30-day clock to the credit-decision notice, per Comment 9(a)(1)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - application-complete
  - 30-day-clock
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 9(a)(1)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "1. Timing of notice\u2014when an application is complete. Once a creditor has obtained all the information it normally considers\
      \ in making a credit decision, the application is complete and the creditor has 30 days in which to notify the applicant of the credit decision.\
      \ (See also comment 2(f)-6.)"
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 9(a)(1)-1.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the application-tracking system mark completeness at the point all normally-considered information is obtained, and start\
    \ the 30-day \xA71002.9(a)(1) decision-notice clock from that completeness point?"
  file_review: Pull files; confirm the completeness flag fired when normally-considered information was in hand and the decision notice landed
    within 30 days of that point.
  judgment: false
  feeds:
  - reg-b-1002.9-a1-30-day-notification
- id: reg-b-1002-supp-i-9a1-incomplete-denial
  canonical_id: reg-b-1002-supp-i-9a1-incomplete-denial
  section: "Supplement I \u2014 Comment 9(a)(1)-4: Incomplete application denied for non-incompleteness reasons"
  description: "The Bureau interprets \xA71002.9(a)(1) such that when an application\nis missing information but provides sufficient data for\
    \ a credit\ndecision, [LENDER] may evaluate the application, make its credit\ndecision, and notify the applicant. If credit is denied, the\n\
    applicant must be given the specific reasons for denial (or notice\nof the right to receive them); in this instance, missing information\n\
    or \"incomplete application\" cannot be given as the reason for the\ndenial.\n"
  interprets: reg-b-1002.9-a1-30-day-notification
  type: do
  audit_question: For every [LENDER] credit denial where the application was missing some information but enough for a decision, does the adverse-action
    notice cite the specific underwriting reason for denial (not "incomplete application") per Comment 9(a)(1)-4?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-adverse-action
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - denial-reasons
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 9(a)(1)-4"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "4. Incomplete application\u2014denial for reasons other than incompleteness. When an application is missing information\
      \ but provides sufficient data for a credit decision, the creditor may evaluate the application, make its credit decision, and notify the\
      \ applicant accordingly. If credit is denied, the applicant must be given the specific reasons for the credit denial (or notice of the right\
      \ to receive the reasons); in this instance missing information or \u201Cincomplete application\u201D cannot be given as the reason for\
      \ the denial."
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 9(a)(1)-4.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the missing-info-but-decidable case \u2014 so that when [LENDER] denies on the merits, the notice\
    \ cites the specific underwriting reason and never gives 'incomplete application' or missing information as the denial reason?"
  file_review: Pull denials where the application was missing some information but enough for a decision; the compliance person judges whether
    the stated reason is the substantive underwriting reason rather than an impermissible 'incomplete application' reason.
  judgment: true
  feeds:
  - reg-b-1002.9-b2-specific-reasons
- id: reg-b-1002-supp-i-9a1-counteroffer-combined
  canonical_id: reg-b-1002-supp-i-9a1-counteroffer-combined
  section: "Supplement I \u2014 Comment 9(a)(1)-6: Counteroffer combined with adverse-action notice"
  description: "The Bureau interprets \xA71002.9(a)(1) such that [LENDER] that gives\nthe applicant a combined counteroffer and adverse-action\
    \ notice\nthat complies with \xA71002.9(a)(2) need not send a second adverse-\naction notice if the applicant does not accept the counteroffer.\n"
  interprets: reg-b-1002.9-a1-30-day-notification
  type: do
  audit_question: "For every counteroffer extended to a [LENDER] applicant where the original terms were denied, if [LENDER] uses a combined counteroffer\
    \ + \xA71002.9(a)(2) adverse-action notice, can [LENDER] evidence that no second adverse-action notice was required upon counteroffer non-acceptance,\
    \ per Comment 9(a)(1)-6?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-counteroffer
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - counteroffer
  - adverse-action
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 9(a)(1)-6"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "6. Counteroffer combined with adverse action notice. A creditor that gives the applicant a combined counteroffer and adverse\
      \ action notice that complies with \xA7 1002.9(a)(2) need not send a second adverse action notice if the applicant does not accept the counteroffer."
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 9(a)(1)-6.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the combined counteroffer-plus-adverse-action notice \u2014 so that when a \xA71002.9(a)(2)-compliant\
    \ combined notice was used, no second adverse-action notice is required on counteroffer non-acceptance?"
  file_review: "Spot-check counteroffer files; where a combined notice was used, confirm it met \xA71002.9(a)(2) and that no defective second-notice\
    \ gap exists on non-acceptance."
  judgment: false
- id: reg-b-1002-supp-i-9b2-number-of-reasons
  canonical_id: reg-b-1002-supp-i-9b2-number-of-reasons
  section: "Supplement I \u2014 Comment 9(b)(2)-1: Number of specific reasons (more-than-four threshold)"
  description: "The Bureau interprets \xA71002.9(b)(2) such that [LENDER] must\ndisclose the principal reasons for denying an application or\n\
    taking other adverse action. The regulation does not mandate a\nspecific number of reasons, but disclosure of more than four\nreasons is not\
    \ likely to be helpful to the applicant.\n"
  interprets: reg-b-1002.9-b2-specific-reasons
  type: do
  audit_question: Do [LENDER]'s adverse-action notice templates limit the disclosed principal reasons to (typically) at most four, in line with
    the Comment 9(b)(2)-1 guidance?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-adverse-action
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - specific-reasons
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 9(b)(2)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: 1. Number of specific reasons. A creditor must disclose the principal reasons for denying an application or taking other
      adverse action. The regulation does not mandate that a specific number of reasons be disclosed, but disclosure of more than four reasons
      is not likely to be helpful to the applicant.
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 9(b)(2)-1.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: Do the adverse-action templates facilitate disclosure of the principal reasons while reflecting the Comment 9(b)(2)-1 guidance
    that more than four reasons is unlikely to help the applicant?
  file_review: Review templates and a sample of issued notices; confirm the disclosed principal reasons are typically held to four or fewer.
  judgment: false
- id: reg-b-1002-supp-i-9b2-combined-ecoa-fcra
  canonical_id: reg-b-1002-supp-i-9b2-combined-ecoa-fcra
  section: "Supplement I \u2014 Comment 9(b)(2)-9: Combined ECOA-FCRA disclosures"
  description: "The Bureau interprets \xA71002.9(b)(2) such that disclosing that a\ncredit report was obtained and used in the denial of the\n\
    application, as the FCRA requires, does NOT satisfy the ECOA\nrequirement to disclose specific reasons. Disclosing FCRA key\nfactors that\
    \ adversely affected the consumer's credit score also\ndoes NOT satisfy the ECOA specific-reasons requirement. To satisfy\n\xA71002.9(b)(2)\
    \ [LENDER] must disclose the substantive specific\nreasons (e.g., \"delinquent credit obligations\") in addition to any\nFCRA disclosures.\n"
  interprets: reg-b-1002.9-b2-specific-reasons
  type: do
  audit_question: "For every [LENDER] adverse-action notice issued in part on the basis of credit-report information, does the notice disclose\
    \ substantive ECOA specific reasons (e.g., \"delinquent credit obligations\") AND the required FCRA disclosures separately \u2014 never collapsing\
    \ them \u2014 per Comment 9(b)(2)-9?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-adverse-action
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - fcra
  - origination
  - combined-disclosures
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 9(b)(2)-9"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "9. Combined ECOA-FCRA disclosures. The ECOA requires disclosure of the principal reasons for denying or taking other adverse\
      \ action on an application for an extension of credit. The Fair Credit Reporting Act (FCRA) requires a creditor to disclose when it has\
      \ based its decision in whole or in part on information from a source other than the applicant or its own files. Disclosing that a credit\
      \ report was obtained and used in the denial of the application, as the FCRA requires, does not satisfy the ECOA requirement to disclose\
      \ specific reasons. For example, if the applicant's credit history reveals delinquent credit obligations and the application is denied for\
      \ that reason, to satisfy \xA7 1002.9(b)(2) the creditor must disclose that the application was denied because of the applicant's delinquent\
      \ credit obligations."
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the Comment 9(b)(2)-9 operative

      lead-in (through "delinquent credit obligations."); the FCRA-

      score-factor sub-rule and sample-form reference that follow are

      paraphrased in description.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the ECOA-vs-FCRA distinction \u2014 so that when a credit report drove the denial, the notice\
    \ states the substantive ECOA specific reason (e.g., 'delinquent credit obligations') AND the FCRA disclosures separately, never collapsing\
    \ the FCRA 'report obtained' or key-factor language into the ECOA specific-reasons slot?"
  file_review: Pull credit-report-based denials; the compliance person judges whether a substantive ECOA specific reason is stated in addition
    to the FCRA disclosures, rather than the FCRA language standing in for it.
  judgment: true
  feeds:
  - reg-b-1002.9-b2-specific-reasons
- id: reg-b-1002-supp-i-9g3-third-party-liability
  canonical_id: reg-b-1002-supp-i-9g3-third-party-liability
  section: "Supplement I \u2014 Comment 9(g)-3: Third-party notice \u2014 liability of creditor"
  description: "The Bureau interprets \xA71002.9(g) such that when notice is to be\nprovided through a third party, [LENDER] is not liable for\
    \ an act\nor omission of the third party that constitutes a Reg B violation\nif [LENDER] accurately and in a timely manner provided the third\n\
    party with the information necessary for the notification and\nmaintains reasonable procedures adapted to prevent such violations.\n"
  interprets: reg-b-1002.9-g-third-party-applications
  type: do
  audit_question: "When [LENDER] relies on a third party to issue its \xA71002.9 adverse-action notice, can [LENDER] evidence (i) timely and accurate\
    \ transmission of notice-required information, and (ii) reasonable procedures to prevent third-party violations, per Comment 9(g)-3?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - third-party-notice
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 9(g)-3"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "3. Third-party notice\u2014liability. When a notice is to be provided through a third party, a creditor is not liable for\
      \ an act or omission of the third party that constitutes a violation of the regulation if the creditor accurately and in a timely manner\
      \ provided the third party with the information necessary for the notification and maintains reasonable procedures adapted to prevent such\
      \ violations."
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 9(g)-3.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program facilitate the third-party-notice safe harbor \u2014 timely and accurate transmission of the notice-required\
    \ information to the third party, plus reasonable procedures adapted to prevent third-party Reg B violations?"
  file_review: For files where a third party issued the notice, confirm the transmission record (timely + accurate) and review the procedures;
    the compliance person judges whether the procedures are reasonably adapted to prevent violations.
  judgment: true
- id: reg-b-1002-supp-i-12b-electronic-records-permitted
  canonical_id: reg-b-1002-supp-i-12b-electronic-records-permitted
  section: "Supplement I \u2014 Comment 12(b)-1: Computerized/electronic record copies acceptable"
  description: "The Bureau interprets \xA71002.12(b) such that copies of the original\nrecord include carbon copies, photocopies, microfilm or\
    \ microfiche,\nor copies produced by any other accurate retrieval system (such as\ndocuments stored and reproduced by computer). [LENDER]\
    \ using a\ncomputerized or mechanized system need not keep a paper copy of a\ndocument (for example, an adverse-action notice) if it can\n\
    regenerate all pertinent information in a timely manner for\nexamination or other purposes.\n"
  interprets: reg-b-1002.12-b1-25-month-application-retention
  type: maintain
  audit_question: Does [LENDER]'s ECOA record-retention infrastructure support timely regeneration of any pertinent document (e.g., adverse-action
    notice) from computerized storage, per Comment 12(b)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - recordkeeping
  - electronic-records
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 12(b)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: 1. Copies. Copies of the original record include carbon copies, photocopies, microfilm or microfiche copies, or copies produced
      by any other accurate retrieval system, such as documents stored and reproduced by computer. A creditor that uses a computerized or mechanized
      system need not keep a paper copy of a document (for example, of an adverse action notice) if it can regenerate all pertinent information
      in a timely manner for examination or other purposes.
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 12(b)-1.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: Does [LENDER]'s ECOA record-retention infrastructure support timely regeneration of any pertinent document (e.g., an adverse-action
    notice) from computerized/mechanized storage, so a paper copy need not be kept (Comment 12(b)-1)?
  file_review: Test a sample retrieval; confirm the system can regenerate all pertinent information for a retained record in a timely manner for
    examination.
  judgment: false
- id: reg-b-1002-supp-i-13a-principal-residence
  canonical_id: reg-b-1002-supp-i-13a-principal-residence
  section: "Supplement I \u2014 Comment 13(a)-2: Principal residence requirement (vacation/rental excluded)"
  description: "The Bureau interprets \xA71002.13(a) such that the \xA71002.13\nmonitoring-information requirements apply only if an application\n\
    relates to a dwelling that is or will be occupied by the applicant\nas the principal residence. A credit application related to a\nvacation\
    \ home or a rental unit is not covered. In the case of a\ntwo-to-four-unit dwelling, the application is covered if the\napplicant intends\
    \ to occupy one of the units as a principal\nresidence.\n"
  interprets: reg-b-1002.13-a1-monitoring-info-required
  type: do
  audit_question: "Does [LENDER]'s application-routing logic apply \xA71002.13 monitoring-information collection ONLY to applications for principal-residence\
    \ dwellings (including owner-occupied units in 2-4 unit properties), and skip it for vacation homes and rental units, per Comment 13(a)-2?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - monitoring-information
  - principal-residence
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 13(a)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "2. Principal residence. The requirements of \xA7 1002.13 apply only if an application relates to a dwelling that is or will\
      \ be occupied by the applicant as the principal residence. A credit application related to a vacation home or a rental unit is not covered.\
      \ In the case of a two-to four-unit dwelling, the application is covered if the applicant intends to occupy one of the units as a principal\
      \ residence."
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 13(a)-2.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the principal-residence scope of \xA71002.13 monitoring collection \u2014 applying it to principal-residence\
    \ dwellings (including an owner-occupied unit in a 2-4 unit property) and skipping vacation homes and rental units (Comment 13(a)-2)?"
  file_review: Spot-check the application-routing logic and a sample of files; confirm monitoring collection fired on principal-residence applications
    and was correctly suppressed on vacation/rental applications.
  judgment: false
- id: reg-b-1002-supp-i-13a-not-covered-transactions
  canonical_id: reg-b-1002-supp-i-13a-not-covered-transactions
  section: "Supplement I \u2014 Comment 13(a)-5: Home-improvement/debt-consolidation/HELOC not covered"
  description: "The Bureau interprets \xA71002.13(a) such that the information-\ncollection requirements apply to applications for credit primarily\n\
    for the purchase or refinancing of a dwelling that is or will\nbecome the applicant's principal residence. Applications for credit\nsecured\
    \ by the applicant's principal residence but made primarily\nfor a purpose other than purchase or refinancing (such as home-\nimprovement\
    \ and debt-consolidation loans) are not subject to the\ninformation-collection requirements. A HELOC application is not\nsubject to \xA71002.13\
    \ unless it is readily apparent to [LENDER] when\nthe application is taken that the primary purpose of the line is\nfor purchase or refinancing\
    \ of a principal dwelling.\n"
  interprets: reg-b-1002.13-a1-monitoring-info-required
  type: do
  audit_question: Does [LENDER]'s monitoring-information collection logic skip dwelling-secured applications whose primary purpose is home improvement,
    debt consolidation, or open-end HELOC (unless primary purpose is purchase/refi of principal dwelling), per Comment 13(a)-5?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - monitoring-information
  - exemption
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 13(a)-5"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: 5. Transactions not covered. The information-collection requirements of this section apply to applications for credit primarily
      for the purchase or refinancing of a dwelling that is or will become the applicant's principal residence. Therefore, applications for credit
      secured by the applicant's principal residence but made primarily for a purpose other than the purchase or refinancing of the principal
      residence (such as loans for home improvement and debt consolidation) are not subject to the information-collection requirements. An application
      for an open-end home equity line of credit is not subject to this section unless it is readily apparent to the creditor when the application
      is taken that the primary purpose of the line is for the purchase or refinancing of a principal dwelling.
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 13(a)-5.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the program account for the purpose-based carve-out \u2014 so that dwelling-secured applications whose primary purpose\
    \ is home improvement or debt consolidation, and HELOC applications (unless primary purpose is purchase/refi of a principal dwelling and readily\
    \ apparent at application), are excluded from \xA71002.13 monitoring collection (Comment 13(a)-5)?"
  file_review: Spot-check dwelling-secured non-purchase/non-refi files (home improvement, debt consolidation, HELOC); confirm monitoring collection
    was correctly suppressed except where a HELOC's purchase/refi purpose was readily apparent at intake.
  judgment: false
- id: reg-b-1002-supp-i-14a1-coverage-business-purpose
  canonical_id: reg-b-1002-supp-i-14a1-coverage-business-purpose
  section: "Supplement I \u2014 Comment 14(a)(1)-1: Coverage extends to business-purpose first-lien-dwelling credit"
  description: "The Bureau interprets \xA71002.14 such that \xA71002.14 covers\napplications for credit to be secured by a first lien on a dwelling\n\
    (as defined in \xA71002.14(b)(2)), whether the credit is for a\nbusiness purpose (e.g., a loan to start a business) or a consumer\npurpose\
    \ (e.g., a loan to purchase a home).\n"
  interprets: reg-b-1002.14-a1-copy-of-appraisal
  type: do
  audit_question: "Does [LENDER]'s appraisal-delivery workflow apply \xA71002.14 to all first-lien-on-a-dwelling credit applications, including\
    \ business-purpose loans where the security is a first lien on a dwelling, per Comment 14(a)(1)-1?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-b
  - supplement-i
  - commentary
  - ecoa
  - origination
  - appraisal
  - business-purpose
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 14(a)(1)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: "1. Coverage. Section 1002.14 covers applications for credit to be secured by a first lien on a dwelling, as that term is\
      \ defined in \xA7 1002.14(b)(2) , whether the credit is for a business purpose (for example, a loan to start a business) or a consumer purpose\
      \ (for example, a loan to purchase a home)."
    drafter_attestation: 'Copied verbatim from snapshot 10df644d0120766e (content.txt) at

      2026-05-22T19:00Z. Substring is the full Comment 14(a)(1)-1.

      '
  promoted_at: '2026-05-22T18:48:55+00:00'
  promoted_from: reg-b-1002-supplement-i-roundb-v1.yaml
  program_review: "Does the appraisal-delivery workflow account for \xA71002.14 coverage of ALL first-lien-on-a-dwelling credit applications \u2014\
    \ including business-purpose loans secured by a first lien on a dwelling, not just consumer-purpose ones (Comment 14(a)(1)-1)?"
  file_review: "Spot-check business-purpose first-lien-dwelling files; confirm the \xA71002.14 appraisal-delivery requirements were applied."
  judgment: false
- id: reg-b-1002-supp-i-5d1-indirect-marital-disclosure-enumerated-items
  canonical_id: reg-b-1002-supp-i-5d1-indirect-marital-disclosure-enumerated-items
  section: "Supplement I \u2014 Comment 5(d)(1)-1: Indirect disclosure of marital status \u2014 enumerated items (chapeau recall fix)"
  description: "The enumerated provisions following the chapeau of Supplement I \u2014 Comment 5(d)(1)-1: Indirect disclosure of marital status,\
    \ dropped by the original extraction and restored verbatim from the snapshot."
  type: do
  tags:
  - chapeau-recall
  - regulator-direct
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1002 \u2014 Comment 5(d)(1)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1002
    snapshot_id: 10df644d0120766e
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
    paragraph_quote: i. The applicant's obligation to pay alimony, child support, or separate maintenance income. ii. The source of income to
      be used as the basis for repaying the credit requested, which could disclose that it is the income of a spouse. iii. Whether any obligation
      disclosed by the applicant has a co-obligor, which could disclose that the co-obligor is a spouse or former spouse. iv. The ownership of
      assets, which could disclose the interest of a spouse. Paragraph 5(d)(2).
    drafter_attestation: "Captured verbatim (whitespace-normalized) from snapshot 10df644d0120766e as the enumerated list immediately following\
      \ the chapeau 'For example, the creditor may ask about:'. List boundary captured conservatively \u2014 REVIEW the end boundary before promote."
  judgment: false
  promoted_at: '2026-06-16T19:35:52+00:00'
  promoted_from: reg-b-1002-supplement-i-chapeau-recall-v1.yaml
  source_provenance:
    source_id: reg-b-1002-supplement-i
    fetched_at: '2026-05-22T18:23:05Z'
    content_hash: sha256:0ceeb083eb8b85d8c007f79422c74a907c03a6a559e7f749321d57072e0f35bb
_promotion_history:
- promoted_at: '2026-05-22T18:48:55+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\reg-b-1002-supplement-i-roundb-v1.yaml
  candidates_promoted: 21
  candidates_skipped_existing: 0
- promoted_at: '2026-06-16T19:35:52+00:00'
  candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\chapeau-recall\reg-b-1002-supplement-i-chapeau-recall-v1.yaml
  candidates_promoted: 1
  candidates_skipped_existing: 0
- promoted_at: '2026-06-16T19:38:24+00:00'
  candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\chapeau-recall\reg-b-1002-supplement-i-chapeau-recall-v1.yaml
  candidates_promoted: 0
  candidates_skipped_existing: 1
- promoted_at: '2026-06-16T19:39:12+00:00'
  candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\chapeau-recall\reg-b-1002-supplement-i-chapeau-recall-v1.yaml
  candidates_promoted: 0
  candidates_skipped_existing: 1
