Warren Dennis: A Fair Lending Legend
On January 31, 2004, we lost a fair lending legend. Warren Dennis was an individual who made a huge difference in the world of fair lending. Warren was almost single-handedly responsible for the major cases brought by the US Department of Justice to enforce the Fair Housing Act.
When we look at compliance, we usually start with laws and regulations. We also include enforcement actions and policies. This makes for a large pile of information which gathers a force of its own. Not often do we actually think that one person can make a difference in the shape of that pile - and in the lives of people the laws affect. Warren Dennis was such a person.
Warren began his career in 1972 as an attorney in the Civil Rights Division of the US Department of Justice. As a person and as a professional, he was committed to the concept of fair housing and to the role of the DOJ in making fair housing a reality. As a lawyer, he was, quite simply, the best.
Warren was the individual whose energy and insight shaped the course of fair lending as we know it today. When we explain the difference between inquiries and applications, we are using Warren's words. When we train examiners and lenders in the art of fair lending, we are following Warren's lead.
Warren started his legal and fair lending career at the U. S. Department of Justice. He was part of the team (the most convincing part) that persuaded agencies such as the Federal Home Loan Bank Board to take the Fair Housing Act seriously. It took numerous meetings - often lengthy - but Warren never gave up.
Warren's skill, his special way with words, and his determination always carried the day. He was impossible to resist. He was also a gifted speaker, able to mix humor and information into a mix the audience could tolerate. When I shared the program with Warren, I always tried to go first because he was a very tough act to follow.
Once he had persuaded the bank regulatory agencies to do something about fair housing, he traveled across the country training examiners. He designed the content and format of the original fair lending training. Then he got on airplane after airplane to help deliver it. And when Warren was finished, the examiners were on board.
Warren tackled fair housing from many directions. He was the moving force behind the DOJ lawsuit against the appraisal societies, successfully making the argument that there was such a thing as discrimination in appraisals and that such discrimination violates the Fair Housing Act. As the direct result of his work, appraisals are both more accurate and more fair today - for everyone.
Once Warren started something, he didn't let go of it. He saw it through to the finish. The DOJ case against the appraisal societies was a long and difficult process. Warren didn't stop with the case. He helped with the solution. The appraisals we work with today, including careful and race-neutral market comparisons, are the result of Warren's work.
Warren put the flesh on the delicate distinctions between inquiries and applications. The refinements that he contributed to the definition provide the foundation for Regulation B's reach into discrimination in the form of discouragement while also making compliance with the definition viable. In fact, Warren's words are in the Official Staff Commentary today.
When Warren left the Department of Justice and joined the private sector, he took his ideals and principles with him. He often represented the underdog and did a great deal of pro bono work. Warren accomplished an incredible amount in his short life. He leaves an impressive legacy. We can truly say that he left the world a better place than it was when he started. Such people are rare. We will miss Warren but always be grateful for the work he did.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 2, 3/04
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