The CFPB recently released its report on fair lending for 2016. The report covered a number of topics related to fair lending, including a summary of their supervisory and enforcement activities. One area addressed was the use of “testers” which involves sending persons of protected and non-protected class status into branch locations to inquire about […]
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In Part 1 of this post I raised the issue of the new HMDA to be reported March 1, 2018, and how this has the potential to alter the fair lending landscape by increasing the level of risk. Below I detail some of the reasons why I believe this is the case. In a future […]
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The update to HMDA reporting is just around the corner, and while most institutions are probably prepared for the data reporting changes, this does not mean those institutions are actually ready. In this series of articles on HMDA 2018, we’ll discuss the fair lending risk implications of the new data that will be made available […]
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In April, the Bureau released its fair lending report for 2016. The report summarizes enforcement actions and supervisory activities conducted in 2016.
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Financial regulatory agencies today are especially focused on risk in their supervision practices. This includes both compliance related matters as well as safety and soundness.
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The ABA has issued a fair lending white paper to Treasury entitled: Fair Lending: Fighting Illegal Discrimination: Promoting Growth for the Whole Community. The paper raises issues with regard to agency regulation and enforcement efforts generally but, more specifically, focuses on the CFPB. It addresses enforcement of redlining, application of disparate impact, and advocates that […]
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In this series of posts, we address types of fair lending discrimination that are commonly recognized by the regulatory and enforcement agencies.
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In this series of posts, we address types of fair lending discrimination that are commonly recognized by the regulatory and enforcement agencies. The points covered are risk areas that are often examined in the course of regulatory reviews.
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There are two major problems with fair lending and commercial loans, but lenders should still be prepared for an increase in scrutiny. The CFPB signaled in December of 2016 that small business lending was one of their priorities for 2017.
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In a previous post, we discussed the binary choice regression model which is often employed in evaluating consistency in underwriting with respect to fair lending laws and regulations. Let’s continue the discussion.
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