Lending? Servicing? Does the institution’s policies and procedures make sufficient references to the fair lending policies or procedures when necessary? Does the institution regularly review and update its fair lending policies and procedures? Are reviews and updates conducted by legal counsel? Does the institution have fair lending related practices that differ from stated in its fair lending policies and procedures? Are independent audit reviews conducted of the Fair Lending Program to ensure practices follow policies and procedures? Are policies and procedures reviewed for disparate treatment or disparate impact risk? Management Oversight Does the institution’s fair lending policies and procedures require board of directors or senior management (“management”) oversight? Does the institution’s policies address management responsibility to develop or approve fair lending policies and procedures? Does the institution’s policies require that management receive regular updates of results of periodic fair lending monitoring, tests and audits? Is there a procedure to provide regular updates of fair lending monitoring, tests and audit results and corrective actions to management? Does management receives regular updates of fair lending monitoring, and audit results?
Lending? Servicing? Does the institution’s policies and procedures make sufficient references to the fair lending policies or procedures when necessary? Does the institution regularly review and update its fair lending policies and procedures? Are reviews and updates conducted by legal counsel? Does the institution have fair lending related practices that differ from stated in its fair lending policies and procedures? Are independent audit reviews conducted of the Fair Lending Program to ensure practices follow policies and procedures? Are policies and procedures reviewed for disparate treatment or disparate impact risk? Management Oversight Does the institution’s fair lending policies and procedures require board of directors or senior management (“management”) oversight? Does the institution’s policies address management responsibility to develop or approve fair lending policies and procedures? Does the institution’s policies require that management receive regular updates of results of periodic fair lending monitoring, tests and audits? Is there a procedure to provide regular updates of fair lending monitoring, tests and audit results and corrective actions to management? Does management receives regular updates of fair lending monitoring, and audit results?
Sample-Fair-Lending-Compliance-Checklist-Ver.-6.9.17.docx