As you know, the Equal Credit Opportunity Act (ECOA) as well as numerous other federal laws & regulations prohibit discrimination in any aspect of a credit transaction. It applies to any extension of credit (from commercial loans to home mortgages), including extensions of credit to small businesses, corporations, partnerships, and trusts.
Though fair lending laws are not new, you and your bank officers and internal auditors will benefit from our comprehensive and effective fair lending assessment review services. Specifically, our analysts perform a comprehensive review of :
- Types of credit product offered
- Credit terms offered
- Credit markets served (consumer, commercial, and residential).
- Special programs for underserved populations.
- Demographic information regarding the institution’s credit markets.
- Decision-making processes regarding credit.
- Loan officer or broker compensation.
- Loan product documentation.
- Availability and ease of assembling relevant documentation.
Through this analysis, our analysts develop focal points for a fair lending review based on the risks and vulnerabilities in the program. By the end of our engagement, you will receive our expert analysis on each component of risk and corrective action recommendations, ensuring that any primary areas of concern are addressed.
Suffice it to say, fair lending is high on the regulatory radar and you should have this area targeted for evaluation based on your bank’s risk profile.
Keep in mind, the consequences of not fully complying with fair lending regulations may be severe — not only financially, but also from a reputation perspective.