Historically, business lending has not been the focus of fair lending reviews during bank examinations. The focus is usually on HMDA reportable applications since government monitoring information (GMI) is available and, therefore, protected and non-protected classes status is readily identifiable. How is that changing today?
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.