What does a Fair Lending exam look for?
The bank examiner is looking at your procedures to make a judgment about the fairness of your bank’s business practices. A statistical review of a bank’s actual performance (including your CRA and HMDA log) and some custom analysis will be conducted to determine if actual discrimination exists.
What is the regulatory expectation for Fair Lending?
The examiner wants to find that bank policies and procedures accurately reflect the bank’s non-discriminatory position on Fair Lending. In addition, the examiner wants to see documentation that your bank is faithfully adhering to the technical consumer disclosure compliance as well as the required record keeping.
In our experience, a bank can fairly easily get into technical compliance with the lending regulations. However, maintaining compliance is another matter. Usually, Fair Lending requires a dedicated compliance person who “owns” this area. We can help design the compliance program and the monitoring systems that will make your bank’s compliance person more efficient and more productive. By helping the bank focus on the risk, it will be possible to achieve and maintain compliance at affordable costs.
I call MAPS when I’m looking to put together a marketing program that will stand up to my compliance officer’s questions. They’re good, fast and so, far, they get a “thumbs up” form the Compliance Department.