Would anyone have a Fair Lending Risk Assessment sample that they would be willing to share? I am in the process of developing one and it would be very helpful to see an actual sample. Thank you!

Use the Interagency Fair Lending Examination guidelines and just go through and use each one of their risk points.

FSBT - what Randy mentioned is the most effective. Each bank is very different, and you need to make the assessment fit your bank. One caveat - many people think of residential loans for fair lending because they are the easiest to dissect because of GMI. You need to document all your lending lines appropriately, so you may be looking at the same questions several times.

The most effective FL Risk Assessment sample that I have found comes from the OCC Community Bank Supervision Handbook (pages 169-172 from the attached link). http://www.occ.gov/publications/publications-by-type/comptrollers-handbook/cbs.PDF

I think this is a little more granular than the Interagency Guidance as it walks you through the specifics of what could create risk (i.e. centralized underwriting vs. decentralized; low number of exceptions vs. a high number of exceptions) - then it lays out some examples of controls you may have in place to mitigate the risks (i.e. second reviews vs. no second review, etc.).

More than anything, I like the way this lays out the risks and controls with the "low, mod, high" & "strong, sat, weak" ratings. I think the regulators are looking for this type of simplified rating for the specific areas so they can see where there may be risks that they can dig into.

I've also seen (as a method for tracking/explaining) where each task (e.g. underwriting) is listed with an inherent risk, compensating factors within the bank, and a residual risk.

Example - Underwriting - Inherent risk High - Bank compensating factors - Centralized underwriting, policy approved by board and adhered to, exceptions well documented/tracked and monitored, all underwriters experienced. Residual Risk - Moderate/Low

Rocky, Good catch on the residual risk rating. That is ultimately how the regulators want us to categorize each lending business.

We also include a 'risk trend' component that shows whether the risk for a particular business is increasing or stable. Increasing may apply to Auto Lending because of recent focus or Mortgage Lending because of the pending HMDA changes. Business Lending could be increasing if the DF Reg B data collection rules would ever materialize.

We also track inherent risk, controls, and residual risk by products and task, then roll up to line of business ratings. Our assessment is based on the FFIEC guidance, but we have added additional fair lending and UDAAP factors based on recent consent orders, regulatory guidance, and exam experiences. As we go through our assessment, we consider findings from testing and reviews by the first, second, and third lines of defense; complaints; regulatory examinations; model validations; etc.