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#1966873 - 10/03/14 03:16 PM Fair Lending Testing - Spreadsheet
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,109
In the mountains
Does anyone have a Fair Lending spreadsheet they would be willing to share for transaction testing?
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Fair Lending
#1967062 - 10/04/14 01:31 PM Re: Fair Lending Testing - Spreadsheet Likes to Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
That is a pretty opened-end question. What type of loans, what are you testing for, etc. There is no one size fits all depending on the risks identified in your fair lending risk assessment and the focal points that you have identified.

A simple one is shown in this document:

https://www.fdic.gov/regulations/resources/side/side.pdf

The ABA also published a good tool for fair lending testing development:

https://www.aba.com/aba/toolbox/FairLending/FairLending_Tool4r.pdf

Just taking some spreadsheet and diving into testing is a very dangerous undertaking. To do fair lending self-testing correctly and have it result in something meaningful takes an awful lot of planning and total buy in by management, the board of director and it never hurts to have legal counsel on board either. Any testing should be conducted under attorney client privilege. While that will not shield the results from your regulator, it will come in handy in case you find something and then any other party brings a civil suit against your bank in the future.
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#1981864 - 12/09/14 04:49 PM Re: Fair Lending Testing - Spreadsheet rlcarey
acquiescent Offline
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acquiescent
Joined: Apr 2014
Posts: 53
Chicago, IL
Great resources, thank you very much for sharing.
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