Thread Starter: Rocky P
Title: Re: Fair Lending Analysis
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No, examiners are not perfect, and just as underwriters can see loans differently and factor the components differently, so do examiners.
There is no right solution for all cases, nor instructions on which is the best way. I generally look at the actions taken to see if the percentage is similar to the other banks in the assessment area and the penetration (comparison) of application and loan percentages based on race and ethnicity to see if they are similar to bank lenders in the assessment area. Larger banks can get more sophisticated but in most cases, decisions of similar percentages and applications and loans from similar race ethnicity percentages are good indicators.
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