Fair Lending Compliance

Fair Lending Risk Assessment

Fair lending risk assessments identify and measure risks inherent in a bank’s lending processes and whether sufficient systems and controls are in place to prevent illegal discrimination.

The scope of a fair lending risk assessment includes the following:

  • Identification of specific risks based on products, services and business lines and review of prior examination reports
  • Review of written policies and procedures for treatment of fair lending topics
  • Evaluation of fair lending implications of marketing strategies and campaigns
  • Review of employee training covering fair lending topics
  • Technical review of adverse action files for ECOA and FCRA compliance and suitability of supporting documentation
  • Review of any in-house analyses of home loan data, loan account geoanalysis or credit decision studies
  • Analysis of HMDA-reported home loan data, if needed to develop approval and denial rates for protected groups and to check for geographic distribution issues
  • Review of samples of approved and denied home loans with borrower and loan characteristics which might be indicative of disparate treatment or underwriting inconsistencies
  • Review of credit underwriting overides or exceptions
  • Review of loan originator compensation
  • Review of third-party referral sources and effects on borrower mix, if applicable


Fair Lending Training

We customize fair lending training for a bank’s employees, officers and directors. Each presentation focuses on the bank’s approach to fair lending, and the level of detail is adjusted for each audience.

We believe that effective training provides directors, officers and employees with a general grasp of the regulatory requirements for fair lending and a more specific understanding of the bank’s specific systems and controls for compliance.