Complianceking - I would also look at your consumer auto and unsecured loans as well. The FDIC is beginning to look at those products for a fair lending comparison based on rates, fees, etc. They will look at whether you are treating those of a prohibited basis fairly. If you have an internal rate sheet, make sure it is followed and if there are exceptions to the pricing - the reasons are clearly documented in the loans files.
Oh and they also will want you to have a Fair Lending Risk Assessment to show what areas are low to high risk based on your Fair Lending Review findings.
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