Fair Lending Plan
Complying with anti-discrimination rules may represent one of the largest efforts of lender's compliance managers. The CFPB, OCC and FDIC all have announced plans to increase supervision. This plan establishes a company's policy basis for Fair Lending compliance, but also addresses support mechanisms such as 2nd level review, application definition, training for personnel, loan level audit and operational review. It is important to note that some elements of Fair Lending documentation are difficult to address strictly in the compliance plan. For instance, you will need to ensure that elements within this plan get reflected in your origination and processing procedures, but particularly in your credit policy and procedures such as those for second level review and origination and marketing policies, are in the compliance plan, but must be integrated with operations. Elements of your own policies, such as these, may be requested in a Fair Lending Examination but are beyond the scope of the Fair Lending Plan.
Disparate Impact
Whether you are a HMDA reporter or not, you can take advantage of our mechanism for performing a regression analysis to determine exposure to potential disparate impact claims.
In addition to the plan, we include a PowerPoint presentation that can be used to conduct Fair Lending Training
Disparate Impact
Whether you are a HMDA reporter or not, you can take advantage of our mechanism for performing a regression analysis to determine exposure to potential disparate impact claims.
In addition to the plan, we include a PowerPoint presentation that can be used to conduct Fair Lending Training
Fair Lending Plan Table of Contents |
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