Category: Fair Lending

Premier Insights - Fair Lending

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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No Recipe May be a Recipe for Disaster

As a New Orleans native, we are very proud of our cooking and food – and, for good reason. My grandmother had to be one of the best cooks that ever walked the face of the earth. No matter the dish, whatever she was serving up was unbelievably good.

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Looking Under The Hood: Do Your Loan Policies Need a Tune-Up?

  A regulatory examination of lending activity, whether fair lending related or safety and soundness, always focuses on data. Data integrity notwithstanding (which is another blog post entirely), such data is a function of (2) things: (1) policies and (2) actual practices. The interaction of these two forces creates the lending data that will be […]

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Fair Lending Pricing Risk: Is There A Storm Coming?

All of us are familiar with the term “perfect storm.”  A perfect storm can be defined as the occurrence of a highly improbable event.   In the context of the perfect storm, the event is improbable because a combination of factors or conditions have to occur or exist either simultaneously or in a particular sequence in […]

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