NCUA Q&As – Is prohibiting a member’s use of unemployment compensation as a source of income a violation of Regulation B?

Compliance > Lending > Fair Lending
Q:   Is prohibiting a member’s use of unemployment compensation as a source of income a violation of Regulation B?
 
A:  When considering income derived from a public assistance program, a creditor may take into account, for example, the length of time an applicant will likely remain eligible to receive such income, whether the applicant will continue to qualify for benefits based on the status of the applicant's dependents (as in the case of Temporary Aid to Needy Families, or social security payments to a minor), or whether the creditor can attach or garnish the income to assure payment of the debt in the event of default.  12 CFR § 1002.6(b)(6) (Staff Commentary).
 
 
ADDITIONAL INFORMATION:
This Q&A was obtained from NCUA’s website, in a document entitled “NCUA Fair Lending Examination and Compliance Program for Federal Credit Unions,” which may be found here: 
 

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