Category: Fair Lending

Fair Lending

Fair Lending Redlining: The Nuances and Challenges of Detecting and Correcting Problems

In our previous post on the topic of redlining, we discussed how redlining is an issue that can have serious consequences for banks that do not adequately manage these risks. However, detecting and correcting redlining issues can be complex and nuanced, which is why it’s important to be proactive in addressing these and other fair […]

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The Role of Fair Lending Risk Assessments in Banking Compliance

Financial institutions are under constant and increasing scrutiny from regulators to manage fair lending risk and ensure compliance with fair lending laws. In this context, conducting fair lending risk assessments is paramount for risk managers who are aiming to not only meet legal requirements, but also promote positive customer outcomes and avoid appearances of practices […]

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The Hidden Dangers of Fair Lending Redlining: How It Can Harm Your Bank and Your Customers

You know the importance of ensuring compliance with fair lending regulations. But have you considered the dangers of redlining specifically and completely? Redlining Defined Redlining is the practice of denying or limiting financial services to certain neighborhoods or areas, often based on factors such as race, ethnicity, or income level. While it is illegal, redlining […]

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Uncharted Waters: 4 Challenges Facing Small Business Lenders Under the Proposed CFPB Rule

Overview Earlier this month, there was a major development that could prove to be very significant in regard to fair lending. On September 1st, the CFPB released its proposed rule regarding small business lending data collection. The rule, mandated under the Dodd-Frank Act, and, if finalized and implemented, will require lenders to collect and report […]

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Redlining Risk & Data Analysis for Fair Lending in a Nutshell

With respect to potential fair lending issues, redlining has remained a significant focus during regulatory examinations for a number of years. There are a number of critical pressure points that should accompany an institution’s self-evaluation of redlining risk. These points are broad and range from marketing efforts, products, branch locations, delineation of assessment and market […]

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There Is No Shortcut to Effective Fair Lending Policy

In previous posts (see The Fair Lending Risk of Good Intentions) we have discussed fair lending risks associated with certain well-intended practices.  In an effort to avoid fair lending risks, institutions may find it tempting to have practices that either favor protected classes or policies that eliminate any variation in pricing or decisioning in an […]

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Important CRA & Redlining Update: It’s Time to Think About 2020

2020?  Yes, 2020.  With the bizarre nature of last year, it is easy to overlook some of the year’s significance.  One is that 2020 was a Decennial Census year, with the population of the U.S. recounted.  It is never too early to think about this as there will likely be changes that will affect those […]

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Cutting Through the Murkiness: Fundamentals of the Comparative Review for Fair Lending

Fair lending concerns are one of the dominant risks lenders face in regard to their business operations. Although larger lenders typically have significant resources in place to mitigate these risks, and there has been an emphasis in the last decade on quantitative methods for fair lending evaluation, there remains a great deal of subjectivity in […]

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Public HMDA 2019 Overview and What Lenders Should Know

Below, we provide a summary of the recently released 2019 HMDA data, and keys for understanding the importance of these data. The Basics Enacted by Congress in 1975, and implemented by Regulation C, the Home Mortgage Disclosure Act (HMDA) is considered “the most comprehensive, publicly available information on mortgage market activity.”  Its purpose is to […]

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Challenges in Fair Lending Analysis, or Why You Don’t Have to Avoid Swimming Pools When Nicolas Cage is Working

The term “Information Age” probably pre-dates many who are reading this post, possibly originating as early as the 1970’s with the proliferation of computer technology.  From the mainframe era, to PC’s, laptops, personal devices and smart phones, technology continues to shape our world at a seemingly ever increasing rate.  This is all augmented by the […]

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