Fair Lending Risk Assessment
The Interagency Fair Lending Examination Procedures have been readily available for many years now but banks continue to be the subject of enforcement actions by their primary regulator and the Department of Justice (DOJ).
A comprehensive fair lending risk assessment based on the Interagency Fair Lending Guidelines is the best method for minimizing the risk of such potential actions. The recently updated Consumer Compliance Rating System makes it very clear that all regulatory agencies expect a robust compliance management system which includes regular self-assessments such as those for fair lending.
A Fair Lending Risk Assessment is an offshoot of your compliance management program risk assessment and typically will include a review, either by an internal party at your bank or by a third party, of your written policies and procedures, monitoring, data analytics and training efforts. To keep you out of the fair lending abyss, we will use recent enforcement actions to help augment your bank’s current fair lending risk assessment program.
One of the primary goals of a fair lending risk assessments is to mitigate the risk of a regulator referral to the DOJ, a downgrade in your examination report, enforcement actions and large penalties. Your regulator is required to refer discrimination cases to the DOJ when it has reason to believe that a creditor has engaged in a pattern or practice of lending discrimination. Don’t be the bank that is the subject of the next referral. Let us show you how to implement or maintain a fair lending risk assessment program.
Upon completion of this program, participants understand how to:
- Develop an Overview of Your Fair Lending Program including Policies, Procedures, Personnel, Underwriting, etc;
- Utilize the Interagency Guidelines in a Question Format That Will Serve as the Framework for the Risk Assessment;
- Identify all Program and Product Risk Factors and Control Elements;
- Conduct Comparative Analysis for Both Redlining and Underwriting;
- Analyze Potential Discriminatory Marketing Practices;
- Factor in the New HMDA Rule to Future Risk Assessments; and
- Factor in the Regulation B Expansion for Data Collection on Loans to Minority Owned, Women Owned and Small Businesses.
The program is designed for compliance officers; auditors; lending department management; loan operations, originations and servicing personnel; loan officers, and others involved in originating or servicing loans of all types.
Don L. Blaine is the Senior Training Consultant for Compliance Resource, LLC, a source of compliance assistance for financial institutions. Don has over 30 years of experience in regulatory compliance for the banking industry with banks ranging in size from community banks to money center banks. He is considered a subject matter expert in many of the consumer affairs laws and regulations and will be primarily specializing in training activities that will encompass the Bank Secrecy Act/Anti-Money Laundering laws and regulations as well as many of the laws and regulations related to deposit compliance. His prior roles have included: Chief Compliance Officer, Senior Compliance Regulatory Examiner, Compliance Audit Manager, and business unit compliance manager. He has taught at the ABA’s National Compliance School and has also served as an instructor on BSA and compliance topics at various programs offered by state banking associations. Prior to joining Compliance Resource, LLC, Don served as a consultant to numerous banks in areas ranging from BSA to lending and deposit compliance. He has attained Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) certifications.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
- Live Webinar which includes 5 Day On-Demand - $265
- Six Month On-Demand – $295
- CD-ROM (Includes Six Month On-Demand) – $345
- Live plus Six Month On-Demand – $365
- Premier (Includes all options) – $395
- Additional Locations – $75
Online: Click here.
Phone: Call Total Training Solutions at (800) 831-0678
Register online up to day of event. Earlier registration allows time to check your computer for an optimal experience.