Most times (for smaller banks) the regulators do not do comparative file reviews unless they suspect the bank is doing things different for some applicants. You might start doing a self assessment and determining your risks. Then, key-off of the higher risk items and work down. (Rank and yank)
Last edited by Southern Banker; 09/13/11 11:07 PM. Reason: added a comment
At a minimum for a comparative file review, they will need 5 prohibited basis denials (same group- all Black, or Hispanic, or female) offset by 20 control group approvals.
Also - make sure that Management and the Board is fully aware of your review and that they have an action plan in the event that something is found.
Integrity. With it, nothing else matters. Without it, nothing else matters.