We have a bankwide Fair Lending Policy that has a small section for Fair Housing. Should we have a separate policy for Fair Housing?

I would say your Fair Lending Policy would be enough.

Are you talking about a fair housing policy, or a fair housing act policy? I had this Fair Lending Act Policy but do not remember the source.

It is the policy of our bank to comply with all aspects of the Fair Housing Act as it applies to the business and operations of the institution. Specifically the bank shall display the Fair Housing Act poster in the lobby of its main office and all of its branches and in each area of its facilities that is specifically designated for the purpose of dealing with residential loan applicants. In all of its advertising of loan products designed to be secured by residential real estate the fair housing symbol and the words “Equal Housing Lender” shall be prominently displayed.

In the event the institution becomes the owner of residential real estate through foreclosure or otherwise, it shall not discriminate on an improper basis in the sale or leasing of the property or in the advertising for the sale or lease of the property.