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#33251 - 09/18/02 11:18 AM Fair Lending Training Requirements
SPF36 Offline
New Poster

Registered: 07/19/02
Posts: 20
Is there a requirement for annual Fair Lending training (FDIC is our regulator)? For all employees? Those in Lending?

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#33252 - 09/18/02 11:24 AM Re: Fair Lending Training Requirements
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50192
Loc: Galveston, TX
There is no regulatory requirement to do fair lending training.

With that said, because everyone else will jump all over it if I don't say it, fair lending training is a must to show good faith compliance with fair lending laws and most institutions conduct it at least annually.
_________________________
The opinions expressed are my own, take them or leave them.

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#33253 - 09/18/02 12:11 PM Re: Fair Lending Training Requirements
ahou Offline
Power Poster

Registered: 08/15/02
Posts: 2703
It is part of our Nondiscrimination program. In Fair Lending Exam procedures of the OTS, they look at training manuals. Even though annual training is not legally required, I feel it shows a good faith effort by the bank. May also help you as a defense in discrimination claims by a community group!
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Opinions are my own and not of my employer.

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#33254 - 09/18/02 11:04 PM Re: Fair Lending Training Requirements
Lucy Griffin Offline

Diamond Poster

Registered: 11/21/00
Posts: 1544
It is definitely a good idea to conduct annual fair lending training. Although not a requirement under Fair Housing or ECOA, you are required to maintain adequate compliance. Training is a key component of that process.

The CRA examination considers whether you have conducted fair lending training annually. So failure to do so could lower your CRA rating.

Training should include anyone who has customer contact with loan applicants. Everyone who has the opportunity to do so should understand not to steer customers to products or specific lending staff based on prohibited basis assumptions. Front line staff doesn't need to get into underwriting issues such as treatment of income, but they do need to know how to give equal service.

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#33255 - 09/26/02 05:48 PM Re: Fair Lending Training Requirements
Anonymous
Unregistered


Lucy, I need training/education in both fair lending and CRA and I notice that you are listed as a speaker at the PCI CRA Colloquium in Denver next month. Would this conference, including the Sunday pre-conference, be appropriate for someone who knows very little about CRA requirements? I need to start somewhere, but my boss is concerned that this particular event might be too advanced. I'd appreciate your thoughts. I'm a loan officer in a small institution and recently have been assigned the task of "getting on top of CRA" before our next exam (expected 1st qtr of 2004).

Cathy Shanelec
cshanelec@lyonsfed.com

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