All in Fair Lending

Overt evidence of disparate treatment is the first type of discrimination recognized by the courts and probably the easiest one to identify in an organization.  This type of discrimination is defined as when a lender openly discriminates on a prohibited basis.  This means that a lender publicly makes a statement or publishes an advertisement that is a blatant statement of discrimination.  A simple example of this would be if...

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...