Fair lending continues to be THE hot topic in 2022, with new developments seemingly every week. New(er) leadership at the regulatory agencies have been outspoken in their new priorities and goals, with terms such as “equity” and “underserved consumers and markets” being mentioned often. This means new requirements and increased enforcement to monitor. And as an added bonus, the CFPB’s latest UDAAP Exam Manual includes discrimination in any aspect of banking as possible UDAAP. Are you keeping up with all the changes that will impact your institution? It is more critical now than ever to ensure your fair lending program covers all the bases. There are new ways of looking at lending patterns, activities, and risks, and new expectations from the agencies.
In this webinar, we’ll go in-depth with a discussion of fair lending principles, expectations, and techniques. We’ll explore what’s new in the area of fair lending, to new interpretations of protected classes, to future potential legislation. We’ll also cover aspects of formulating and maintaining an effective fair lending risk assessment, a critical component of an institution’s fair lending compliance program. We’ll also explore the many risks and hot spots to monitor for fair lending, and discuss how to best comply with the new requirements and expectations. We’ll ensure you’re ready for your next fair lending compliance examination so you can put your best foot forward.
What You’ll Learn
- Fair lending legal and regulatory structure – where these requirements come from
- Expansion of fair lending priorities and expectations – from Congress as well as the regulatory agencies
- Prohibited bases under the rules (what you can do, as well), including changes in definitions – including examples and scenarios
- Fair lending throughout the lending process – from A to Z
- Marketing considerations – putting your best foot forward
- Evaluating applications and underwriting – what you can and cannot consider
- Government monitoring information – when to get it and how to handle it, including the new URLA/1003 application form
- Fair lending litigation trends and lessons, including re-emphasis of disparate impact
- Redlining (including reverse redlining) – what is it, how do we analyze it, and what is new (hint: plenty)
- Digital redlining – what is this and how does it impact your institution? How to look at redlining in the digital age
- REMA/Marketing Area/Service Area – what is this? What should we do to be ready for our next exam?
- Treatment of income and other underwriting issues
- Fair lending issues in the servicing environment, especially debt collection, default management, and foreclosures
- Proxies and the BISG method – should we do this?
- Foreign language and LEP issues – what are the rules?
- CRA as a fair lending tool
- Developing an effective and comprehensive fair lending CMS
- “Convergence” with UDAP/UDAAP – what should we do?
- Appraisal bias and upcoming AVM regulations
- Consequences and enforcement actions
Who Should Attend
Anyone in the institution having virtually any responsibility in the lending process has fair lending responsibilities, from senior management, loan officers, underwriters, and closing agents, to compliance officers, auditors, and attorneys, and would benefit from this valuable information.