Fair Lending Hot Topics in 2017 – What’s On the Horizon?
The October 4, 2016 Interagency Fair Lending Hot Topics included the sessions listed below.
It looks like “redlining” will be a concern by all bank regulators in 2017.
- CFPB Mortgage Updates – Focus on Bancorp South enforcement action for redlining and use of “paired testers”. Also included overview of 2018 HMDA rules that will add MORE data for fair lending analysis
- NEW Compliance & Community Affairs Business Unit – OCC – includes “heightened” focus on Fair Lending
- Redlining Risk – Federal Reserve
- Redlining – A Bank’s Reasonably Expected Market Area, FDIC
- Redlining – Enforcement Section, Department of Justice
How will your regulator evaluate Fair Lending compliance in the next exam? A compliance examination is the “report card” that financial institution regulators use to “pass or fail” a financial institution’s compliance and Fair Lending program. Will your financial institution pass the test?
- New HMDA rules will go into effect in 2018, now is the time to start updating the HMDA data collection process. How will the proposed additional HMDA data fields impact fair lending?
- The FDIC has introduced a new acronym into Fair Lending AND CRA compliance -the REMA – “reasonably expected market area”. Learn the “new normal” of the SEVEN FACTORS used to define a REMA and tips to prove compliance. Review of the 10/27/2016 FDIC presentation on “Determining the Reasonable Expected Market Are for Redlining Analysis”. The FDIC is also focused on THIRD PARTY relationships that may impact fair lending.
- What are the fundamentals of Fair Lending, including best practices for inquiries, loan interviews, application processing, and documenting denials?
- Compensation issues – recent headlines about the abuses of Wells Fargo and pressure to perform will bring more focus to this area.
- What should you know about the interagency Fair Lending examination procedures used by the CFPB, OCC, FDIC, and Federal Reserve?
- How can an effective internal Fair Lending review help detect problems before the examiners arrive? How would your bank be viewed by “paired testers”?
- What should your internal Fair Lending training sessions cover? Who needs the training?
Both experienced and new Compliance Officers, Auditors, Lenders, Loan Operations, Risk Managers, and Senior Management. Requirements for small and large financial institutions are covered. Links will be provided for the CFPB, OCC, Federal Reserve, and NCUA exam procedures.
Susan Costonis is a compliance consultant and trainer. She specializes in compliance management along with deposit and lending regulatory training and began her career in 1978. Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve.
Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real life examples.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
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