Do You Want To Know How Examiners Do A Fair Lending Review?

Here is something I’ve heard all too often from bankers: “The examiners say that we need to do more for fair lending, but we just don’t know what to do.” Sound familiar? They won’t tell you exactly what to do because of liability concerns. If you do the one task they recommend, but then during the next exam there are major areas elsewhere, you could come back and say “well we did what you told us to do.” It really just leaves you scratching your head with no progress towards a stronger program.

If only you could get one of them in your bank to teach you what they know and what to look for. Examiners get great fair lending training, and they do tons of fair lending reviews. There are many tips and tricks they use to determine the strength of your program. Do you want to know what they know? Here is your chance.

I’m a former commissioned examiner with the FDIC. I’ve lead dozens of fair lending reviews over the years. I’ve analyzed HMDA data, performed countless consumer loan pricing reviews, lead a massive comparative file analysis, geocoded loans and bank branches for redlining reviews, investigated and analyzed discriminatory complaints, and so much more. I’ve attended the FDIC’s fair lending course in Washington D.C., and I’ve worked closely with regional office fair lending experts and review examiners on fair lending issues. The best part is I am willing to teach this to you while I perform a comprehensive analysis of your bank’s fair lending efforts.

I’ve built my consulting business around three core ideas: provide high-quality compliance services to community banks; teach the skills I’ve learned to strengthen their compliance program; and all at a price that community banks can realistically afford. My goal is to perform an examination of your fair lending program and then turn around and teach you what I did. Not only will you get an examiner eye of what your doing but the skills to be able to do it yourself. I even sit down with you while you write procedures so that next year, you don’t have to pay for it again. You already know what to do.

There are multiple factors that affect your fair lending program, so each review is different. I will help you find the major risks to your bank and then teach you how to review and mitigate those risks. I can’t teach everything at every review, but here are areas of focus that may concern your bank:

·        Underwriting Analysis

·        Pricing Analysis

·        HMDA Data Analysis

·        Redlining Analysis

·        Product Steering Review

·        Advertising/Marketing

·        Comparative File Analysis

·        Fair Lending Interviews

If you are looking to strengthen your bank’s fair lending program, there is no quicker, more effective, or economical way to do it. Fair lending reviews are typically completed within one week or less, and you will get a written report of the results. Please send me an e-mail to learn more: tory@tcconsulting.us. It doesn't cost you a dime to find out what I can do for you.