Throughout every administration in the last ten years, it has become clear that enforcement of fair lending laws is a high priority. Enforcement actions are not limited to just one or two key issues; there is broad assault on fair lending issues.
A strong fair lending program requires more than simply dotting i’s and crossing t’s. Discrimination can be obvious, subtle, or unintended.
Charges of discrimination can come from any direction. Risk comes in the form of penalties, regulatory enforcement actions, civil liability, or damage to an institution’s reputation, to mention a few. The best defense to these threats and risks is developing and maintaining a sound fair lending compliance management system.
Over the years, fair lending violations have led to consent decrees that include:
- Significant civil monetary penalties
- Huge reputation risks which lead to program requirements (i.e. new locations, stronger vender management etc.)
- Reimbursement to borrowers
- Burdensome remedial action to prevent further violations
What You’ll Learn
- Fair lending concepts:
- Laws and regulations
- Bases of discrimination
- Types of discrimination
- How to mitigate fair lending risk:
- Reviewing policies and procedures for fair lending problems and eliminating those concerns
- Training: Who, How, When, and What
- Monitoring/Auditing
- Exemptions
- HMDA data
- Marketing/Advertising
- Statistical analysis:
- When is such analysis suggested
- How to conduct the analysis
- Should you do it yourself or contract the service
- Recent developments:
- Finalizing Small Business Data Collection and Reporting (Section 1071)
- CRA rules and how they are tied to fair lending programs
- Fair lending enforcement actions
- Redlining cases
Who Should Attend
This session is ideal for members of the board of directors, managers of all lending departments, institution counsel, compliance officers, fair lending and CRA officers, loan officers, and auditors.