For many, the hang-up in fair lending is in the getting their hands dirty performing
their own fair lending comparative file review and performance self assessment. It
can be mind numbing just thinking about getting started.
Much of the fair lending exam scrutiny has been in mortgage lending, as there is a
great deal more data known about each applicant in this lending channel than in
either consumer or commercial lending. Data elements like race, ethnicity, gender,
etc., are required HMDA fields. Having this data offers both a great advantage to you
for self-assessment purposes, but also for the examiners, as well. Self assessments should
ultimately include all lines of business including mortgage, consumer and commercial
when deemed appropriate and review how you have treated prohibited basis groups.
While you can’t collect race, gender, and ethnicity information for non-mortgage loans
(at least not yet) you can utilize proxy data, such as the use of surname (for ethnicity), a
gender-izer, or census tract characteristics – to help determine your performance.
Where do you begin in establishing your own fair lending monitoring program and self
assessment? What can you do to “streamline” your fair lending examination? To answer
that, we must first identify “what do the examiners expect it to include?” It is our hope
that you gain a working knowledge of the basic elements of fair lending monitoring and
self assessments from reading the following white paper. You can add greatly to your
knowledge by attending conferences hosted by the regulators, vendors and national
trade associations. It will also help you to simply, get started. Experience may be the
Want more information? Complete this form and we’ll contact you immediately.