Category: Fair Lending

Premier Insights - Fair Lending

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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CFPB Annual Fair Lending Report Addresses Small Business Lending

The Bureau of Consumer Financial Protection issued its seventh Fair Lending Report to Congress.  The report, released June 28, 2019, describes the Bureau’s fair lending activities in prioritization, supervision, enforcement, rulemaking, interagency coordination, and outreach for calendar year 2018.

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Maintaining Proper Perspective of Statistical Methods for Fair Lending Evaluation

We have discussed previously in various posts some of the challenges of using regression and other statistical methods for fair lending reviews as well as the current emphasis on quantitative methods.   Over the last 10 years, the regulatory and enforcement agencies as well as institutions have been gravitating more and more towards statistical methods when […]

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The Importance of Product & Service Training To Enhance Fair Lending Compliance

In previous posts we have emphasized the importance of customer service as an aspect of managing fair lending risk. Since fair lending deals primarily with treatment of applicants, and the agencies recognize that discrimination can take place at any aspect of the transaction, inconsistency in levels of service could constitute fair lending risk. Consequently, having […]

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FDIC Chair McWilliams Addresses “Regulatory Tone” In Examinations

In a speech earlier this year, FDIC Chair Jelena McWilliams provided some insights concerning her vision with regard to bank regulation. 

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