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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CRA Tips and Tricks for Intermediate-Small Banks
Overview of Flood Insurance Requirements
CRA Mistakes
Fair Lending and Commercial Applications
Assessment Area delineation your most important CRA decision
Fair Lending in 2021
What Community Development really means under CRA
National Defense Act impacts on BSA/AML
The Pandemic and CRA
Compliance Management Systems and COVID
Major changes contained in the Federal Reserve Board's Advanced Notice of Proposed Rule-Making regarding the Community Reinvestment Act.
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