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Equal Credit Opportunity Act (ECOA) baseline review procedures

Updated Apr. 1, 2019


The Equal Credit Opportunity Act (ECOA) Baseline Review Modules will be used by examiners during ECOA baseline reviews to identify and analyze risks of ECOA violations, to facilitate the identification of certain types of ECOA and Regulation B violations, and to inform fair lending prioritization decisions for future Consumer Financial Protection Bureau (CFPB) reviews. ECOA baseline reviews are one type of fair lending review conducted by the CFPB, in addition to ECOA targeted reviews and Home Mortgage Disclosure Act (HMDA) reviews. An ECOA targeted review includes an in-depth look at a specific area of fair lending risk, and is conducted using the ECOA Examination Procedures within the CFPB Supervision and Examination Manual. A HMDA review includes transactional testing for HMDA data accuracy, and is conducted using the HMDA Examination Procedures within the CFPB Supervision and Examination Manual.

When a baseline review is scheduled, examiners will work with the Office of Fair Lending and with CFPB regional management to determine which ECOA Baseline Review Modules will be completed. Once the appropriate modules have been selected, and in advance of the review, examiners will send the institution information requests that correspond with the selected modules. In general, examiners will complete the modules during the on-site portion of the review. In some instances it may be possible for examiners to begin completing the modules prior to the on-site portion of the review. The completed modules will be included in the examination work papers and may be considered in conjunction with any fair lending statistical analysis to obtain a full picture of fair lending compliance and fair lending risks at the entity.

In addition to responses to information requests, examiners may review other sources of information to complete the modules, including publicly available information about the entity and information obtained at interviews or other supervisory meetings with the entity.

Where applicable, the modules include references to relevant Scoping Risk Factors in Part I of the Interagency Fair Lending Examination Procedures (e.g., O1, U1) or the Code of Federal Regulations (e.g., 12 CFR 1002.9). These references are included in parentheses at the end of specific steps.