were resolved on a reasonable basis Analysis of approval/denial Analysis of approval/denial The underwriting process is rates show no significant rates show differences not centralized and high disparity based on any between protected classes. volume of consumer loans prohibited factor. Analysis of Analysis of the loan are originated in several the loan rate/terms/fees for rate/terms/fees for approved geographies and by third approved loans show no loans show some limited parties, including mortgage significant disparity on a differences on a prohibited brokers. prohibited basis. basis. Marketing practices are very Marketing practices do Marketing images are clearly limited and show no include more images of targeted to only one segment evidence that would individuals than of the population. There are discourage a protected class members. A no images of protected “reasonable from applying for a potential for discouragement classes and no minority person” loan. exists. employees in any significant public contact position. The interagency fair lending procedures were updated in August of 2009, the link to the procedures can be found at: Many financial institutions are reporting that examiners are doing more in-depth interviews with loan officers and may routinely ask for the resumes of new loan officers. Fair lending risks can be mitigated through these steps: Training THIS IS A HOT BUTTON – Monitoring pricing and policy exceptions Reporting exceptions to the Board and/or Audit committee for review Changing policy if there are excessive continued exceptions Limiting any discretion in loan pricing Requiring documentation of lending decisions Completing a fair lending risk assessment
were resolved on a reasonable basis Analysis of approval/denial rates show no significant disparity based on any prohibited factor. Analysis of the loan rate/terms/fees for approved loans show no significant disparity on a prohibited basis. Analysis of approval/denial rates show differences between protected classes. Analysis of the loan rate/terms/fees for approved loans show some limited differences on a prohibited basis. The underwriting process is not centralized and high volume of consumer loans are originated in several geographies and by third parties, including mortgage brokers. Marketing practices are very limited and show no evidence that would discourage a “reasonable person” from applying for a loan. Marketing practices do include more images of individuals than protected class members. A potential for discouragement exists. Marketing images are clearly targeted to only one segment of the population. There are no images of protected classes and no minority employees in any significant public contact position. The interagency fair lending procedures were updated in August of 2009, the link to the procedures can be found at: Many financial institutions are reporting that examiners are doing more in-depth interviews with loan officers and may routinely ask for the resumes of new loan officers. Fair lending risks can be mitigated through these steps: Training – THIS IS A HOT BUTTON Monitoring pricing and policy exceptions Reporting exceptions to the Board and/or Audit committee for review Changing policy if there are excessive continued exceptions Limiting any discretion in loan pricing Requiring documentation of lending decisions Completing a fair lending risk assessment
FairHOWP060216.docx