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Welcome to Compliance 911, a no-nonsense, cut to the point, style show for today’s busy bank and credit union compliance professionals. With this series of bi-weekly shows our goal is to boil down some of today’s hottest regulatory compliance topics in quick and easy to digest 5-10 minute episodes so you can get the information you want and get on with your day. We’ll be discussing topics like CRA, HMDA, Fair Lending, Anti Money Laundering, and so much more. Don’t forget to subscribe and tell a friend about us! Follow M&M Consulting and GeoDataVision us on LinkedIn to get the latest updates.
Episodes
Jun 19, 2023
Jun 19, 2023
12 min
This podcast episode discusses Fair Lending and focuses on examiner comments and specific examples of issues from regulators. The hosts, Len and Dean, discuss a scenario where a Compliance Officer or Fair Lending Officer in a community bank reviews loans for evidence of disparate treatment (Redlining). They find a series of portfolio loans where the borrowers received more favorable terms in the form of a better rate, and in each case, all were white men applying alone. Upon further review, they find that these exceptions were never submitted to the loan committee for approval, which is required by policy.
The episode then lists several examiner comments on Fair Lending, including appropriate documentation of exceptions within files, tracking mechanisms for exceptions, and reviewing exception log reports periodically. They caution against the quality of fair lending risk assessments, which must include sufficient qualitative and quantitative detail as to the overall risk profile of the institution.
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