Does anyone have Fair Lending audit procedures, you'd be willing to share?

I use the fair lending exam procedures located at this link:

http://www.ffiec.gov/pdf/fairlend.pdf

SG, if you want, you can use the Interagency Fair Lending guidelines, or the OCC version of it. Both are available on-line. [Dani beat me to it!!!]

Rant - Be very careful what you start though, and make sure it is under the guidance of executive management and bank counsel. If there is a finding, the bank needs to have plans (in advance) on how they will handle it.

Fair Lending should not the kind of audit that is done in a vacuum - the bank's findings will be reviewed by regulators and if any cases of Disparate Impact or Treatment are noted, it could result in a referral to the DOJ.

Thanks for the help!

Just to tag on to SB's comments above.

Do be careful when you start scoping your review based on your identified focal points. If you are going to perform this review in-house, it would naturally follow your risk assessment (following exam procedures). Since any "self test" under Reg. B is subject to your examiner's review and use against you (as is the practice with examiners in the current fair lending enforcement environment), I would suggest that if there is an area where you KNOW there is a problem, that you implement a fix first and then have it tested post fix.