Fair Lending Assessments: Know Where Your Risk Is!
September 24 2020 16:00 - 17:00 UTC
Unfortunately, you cannot eliminate inherent fair lending risk. The key is knowing where your vulnerabilities are and taking all appropriate steps to prevent discrimination in any form.
The inbound bogey that flashes ominously on our fair lending radar is that intent to discriminate is not the litmus test for a fair lending violation. The bogey is currently larger due to COVID-19 relief, events in society, and the water hose of SBA PPP Lending and the mortgage interest rate environment. This session is designed to help you take a comprehensive, objective look at your fair lending program, market demographics and lending operations to identify where potential disparate treatment, disparate impact or redlining could occur.
This session will help you:
- Develop a comprehensive internal fair lending risk assessment
- Evaluate lending activity in light of market demographics
- Understand the current and emerging regulatory focus, adapt to changing culture dynamics, and adapt to changing dynamics in the regulatory culture around lending discrimination
- Identify potential land mines in your lending policies, operations and internal controls that can cause significant harm if not recognized and addressed
- Institute appropriate monitoring and reporting mechanisms to identify any potential prohibited bias and ensure the Board and Management are armed with sufficient and meaningful information to gauge the institution’s overall fair lending risk
- Integrating Complaint Management into everyday culture
- Tell your story! There may be perfectly legitimate and supportable reasons for decisions made that may, on the surface, appear to indicate potential fair lending risk. Optics don’t tell the whole story, so be prepared to explain potential disparities if they exist.
- Fair Lending
Fair Lending Risk Assessment Sample (1).docxAttendees Only
Fair Lending Assessments - Sept 2020.pdfAttendees Only
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