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#1926867 - 05/27/14 09:34 PM Fair Lending training
Trees Offline
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We use a well known software for training online. They have a fair lending module that we have everyone take. lenders, in addition, take separate modules for ECOA, etc. Consultants we use say that the Fair Lending training should include CRA, HMDA, etc. for everyone. Not sure I have seen that before. For lenders, yes. For loan admin clerks, tellers, etc. not so sure. We would like to hear about your fair lending training, esp. the components provided to non-lending staff. Thanks.

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Fair Lending
#1926889 - 05/27/14 11:40 PM Re: Fair Lending training Trees
Rocky P Offline
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Florida
Customer contact personnel should be aware of encouraging applications for all potential applicants, understanding that everyone is treated the same per law, policies and practices and who the appropriate officers are for additional questions. That covers (IMHO) their needs for Fair Lending, CRA and HMDA. While the comment is nice, training needs to be specific.
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#1927048 - 05/28/14 03:37 PM Re: Fair Lending training Trees
Trees Offline
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We cover those concepts for all staff. The online courses for HMDA and CRA are very technical and long. We thought we could add some additional points to the current training and that would cover the non-lending staff.

Thanks for the comments.

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#1927851 - 05/29/14 09:51 PM Re: Fair Lending training Trees
TMortgman Offline
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Washington, DC MSA
Working on exactly this right now - have a Fair Lending Plan, and a powerpoint that covers everything for line staff in detail, such as discouragement, preapprovals, prequals and apps, integration into Fair Housing, etc. We also include the HMDA information (not the detail reporting) but the information on rate spreads, so that the student understands the implementation of the ECOA data. Always worry about boring the line personnel to death with yet ANOTHER compliance training.

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#1927858 - 05/29/14 10:13 PM Re: Fair Lending training Trees
Kathleen O. Blanchard Offline

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Many banks use a film for non-lending staff training, one that shows treatment of people coming to bank to inquire about a loan and how the manner in which they are treated can be discriminatory (promptness of greeting, told to come back another time while another applicant gets right in to see a lender, etc.)

Those positions do not need to know about underwriting etc., they need to learn how to treat people.
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#1929139 - 06/03/14 09:48 PM Re: Fair Lending training Trees
Trees Offline
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We used to use the film. Now we are using an online product that is quite good but that has one Fair lending module that leans heavily to the loan side rather than being general knowledge. I think we will need to come up with our own for non-lending people but that still have face time or phone time with customers.

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#1929183 - 06/04/14 12:44 PM Re: Fair Lending training Trees
A_G Online
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Don't foget to include any state-specific fair lending stuff...
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#1929199 - 06/04/14 01:23 PM Re: Fair Lending training Trees
RR Joker Offline
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A very well-known e training module I used to administer had a Fair Lending for Frontline Personnel and Fairness in Banking that were very good for general staff.
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#1929528 - 06/04/14 08:11 PM Re: Fair Lending training Trees
J2C Offline
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Trees, a lot of modules will also have training titled "Fair Lending Considerations for General Banking" or something along those lines. Or, even "Fair Treatment of Customers". Have you checked your vendor to see if something like that is available?
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#1929730 - 06/05/14 03:19 PM Re: Fair Lending training Trees
bOaty Offline
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I'm looking at developing one for loan servicing and loss mitigation, I don't think there is a lot of canned products out there.

There is an article in the most recent ABA Bank Compliance mag that talks about the importance of fair servicing training that is pretty interesting.
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#1949491 - 08/06/14 01:27 PM Re: Fair Lending training bOaty
La. Lady Offline
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WE ARE TRYING TO DEVELOPE A FAIR LENDING TRAINING THAT LEANS TOWARDS THE LOAN SIDE AS OPPOSED TO THE GENERAL RULES. EVERYTIME I PRESENT A FAIR LENDING TRAINING, I AM GOING THROUGH THE SAME HUM-DRUM THAT LOAN OFFICERS HAVE KNOWN FOR YEARS. ADDITIONALLY, THE EXAMINERS STATED THAT OUR TRAINING FOR BOARD WAS NOT SUFFICIENT IN THAT AREA.

OUR BANK USED AN ONLINE TRAINING IN THE PAST FOR EMPLOYEES BUT THEY HAVE DISCONTINUED IT (CEO DECISION)....

ANY IDEAS OF WHAT I COULD DO THAT IS A CHANGE UP FROM THE PAST....
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#1949543 - 08/06/14 02:29 PM Re: Fair Lending training Trees
Rocky P Offline
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Florida
You may talk about things that gets the bank in trouble - an exception for one is discriminating against all that did not get the exception. A favor to one - the same thing. That lending policy while looked at is not as important in a comparative file review, because they look for differences in treatment - basically the least qualified borrower is the new lending benchmark - anyone denied that was better is now a potential target.

That examiners look at all the decisions of the bank (since all decisions are "Bank" decisions) - not on a LO by LO basis. The uniqueness of your policies. Some examples of discrimination and why. Difference in treatment can occur even in the commercial loan departments - why!

AND PLEASE STOP SHOUTING
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#1949552 - 08/06/14 02:37 PM Re: Fair Lending training Rocky P
La. Lady Offline
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Thanks....that helps
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#1961204 - 09/11/14 03:27 PM Re: Fair Lending training Trees
bcompliance Offline
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Is fair lending training required for all employees? If so can someone point me in the direction of where it is cited in regulatory text? Thanks
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#1961212 - 09/11/14 03:40 PM Re: Fair Lending training Trees
rlcarey Online
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Fair lending training is not cited anywhere for anyone. You train people as applicable. For example, if tellers refer people to lending officers for loans, then you train them to refer equitably and what that means.
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#1961217 - 09/11/14 03:44 PM Re: Fair Lending training rlcarey
bcompliance Offline
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Thanks for clarifying that Randy
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