Is your Fair Lending Program in compliance with regulatory requirements and expectations? The compliance umbrella covering Fair Lending touches numerous areas of the FI’s operations, any of which can cause issues if not adequately identified, monitored and mitigated. Board and Management oversight, policies and procedures, audit and monitoring, training, marketing and underwriting practices, and complaint management are just some of the areas where deviation from the FI’s program, can lead to regulatory concern and criticism.
AaSys Group’s fair lending services focus on indicators of discrimination, evidence of disparate treatment, and evidence of disparate impact.
- Does your program meet the requirements of the Equal Credit Operation Act, Regulation B (ECOA) and Fair Housing Act?
- Does your fair lending program cover the entire life cycle of a loan from origination through payoff?
- Is your FI’s redlining risk a concern?
- Do you include consumer, non-real estate lending in your fair lending analysis?
- Is your underwriting process automated or manual?
- Do your lenders have discretion when approving or pricing loans?
- Are your advertising and marketing practices in compliance?
- Do you know what your REMA is?
- How effectively does your FI monitor and analyze pricing and policy exceptions?
- How are loan officers compensated?
- What does the content of your compliance training for your lenders include?
- Are customer complaints analyzed for Fair Lending concerns?
Other key elements of an effective fair lending program in which AaSys Group can assist FIs include:
- Fair Lending Risk Assessment – identify and measure the fair lending risk in your lending processes.
- Internal Monitoring & Corrective Action – confirm your controls are effectively minimizing risk.
- Data Analysis – ensure that your data analysis includes all key factors and that the monitoring and reporting are adequate.