Fair lending is one of the hottest topics in regulatory compliance.  As the dust has settled from TRID and the examiners haven’t quite focused their full efforts on the new HMDA rules, fair lending scrutiny is as intense as it ever has been.  In fact, it always has been a hot topic and will always be one.  One trend new trend that I have been seeing, however, is a demand for community banks and credit unions to conduct a fair lending risk assessment.  

Loan exceptions occur any time a loan file does not meet the established standards for a financial institution.  Lenders typically have guidelines they must follow, and when those guidelines are not exactly adhered to, an exception occurs.  There are typically two types of loan exceptions: 1) Policy exceptions and 2) underwriting exceptions.  Policy exceptions occur when...

Conducting a second review of Adverse Action notices is one of the best ways to reduce fair lending risk.  For this reason, examiners will often recommend a formal process by which to conduct a secondary review of adverse action notices if a bank or credit union does not already have one established.  We believe that a second review should include two parts: 1) a technical...