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The NFICA would provide both a solution to these applicability gaps and an expansive regulatory regime to administer cyberbanking in the future.
In response to the regulatory and Congressional failure to protect those consumers not participating in the surge of cyberbanking activity, and those who might remain unprotected from discrimination in cyberspace should they avail themselves of Internet access, I propose the National Financial Institution Anti-discrimination Cyberbanking Act or NFICA. This Act should be separately enacted and specifically applied to all financial institutions, supplementing the current fair lending and anti-discrimination legislation that applies to such institutions.
NFICA is consistent with the five key policy principles and the nine unresolved major Internet commerce issues identified by the United States government on the future of Internet regulation articulated in a policy statement released in 1997.(170) It is also consistent with the recent OTS decision to evaluate the CRA performance of financial institutions "that deliver their products by non-branch systems [or non-traditional retail operations] throughout the markets where [these institutions] do credit business, not just in the main assessment area."(171)
The NFICA is intended to serve as both a vehicle to apply current anti-discrimination legislation to cyberbanking and to provide a legislative framework for the future enactment and implementation of laws that will control all facets of Internet banking between consumers and financial institutions.
This Act may be cited as the "National Financial Institution Antidiscrimination Cyberbanking Act of 2000," the "NFICA".
[those that have been completed] reveal[] that some depository institutions [have] not always adhered to risk mitigation guidance provided by the regulators."(183) The proposed NFICA, then, is necessary in order to effect the application of fair lending laws to cyberbanking, to minimize compliance risks, and to instill anti-discriminatory safeguards to lending opportunities made available by banks over the Internet.