Does anyone have a resource for an in-depth Fair Lending training seminar or conference? I'm looking at something that goes over the exam procedures and how to do in-depth testing. I'm new in the CRA world (3 years now) and starting to take over the Fair Lending role. I can do cursory reviews but I want to make sure I'm doing and looking at what examiners would do and look at. I'm having trouble finding a training like this. Any suggestions would be appreciated.

Have you looked at the exam procedures for your agency and others? There is often very helpful information prior to the workpapers they use which explain many of the hows and whys.

I've definitely reviewed that document along with IFLEP but documents can't answer questions I encounter as I read them. I'm really surprised there isn't a training out there on performing an internal review. I've done our reviews for a couple years now but I wouldn't know if I'm missing anything - I don't know what I don't know.

So far the best training option given to me is $6,500 plus travel expenses. I guess I'll keep looking.

For Fair Lending, look at your policies and procedures. Then look at your marketing, underwriting and pricing.

For underwriting, identify restrictions, especially as they reflect on housing (including mobile homes), and transportation. Regulators see housing and transportation (get to work, grocery store and medical care) as issues that affect minorities the most. For housing, look at minimum loan amounts (inner city values generally lower) restrictions on terms based on age of mobile homes. Example, 9 years old Mobile home to new = 20 years max while 10 years and older 10-15 year loan max. Many minorities are on the lower end of the income spectrum and something newer would be out of their cost range. Same goes for autos. Cars today are a lot more reliable so a cut-off of 7 years means that the cars will be almost as reliable, but out of price-range. [I have a 12 year old car with 150K miles that has never been in the shop and runs as good as new. Cannot think of any reason to trade it in.} Look for limitations on businesses (e.g. yard maintenance), which are predominantly minority, and phrase it as not lending to new, undercapitalized, etc. businesses. Look at Credit Score cutoffs for both underwriting and terms and conditions, and be able to explain a 1 point difference between a NO at 649 and a YES at 650 (or a 72 month auto loan at FICO 720 while a 719 FICO is capped at 60 months and costs .25% higher.

Marketing - be very careful if the bank is marketing to areas, think new developments) just outside the AA. Read up of REMA (reasonably expected market areas for FDIC, credit market areas FRB.) If lending to non majority-minority areas with MM areas close by, you'll find out what the terms mean real fast - redlining. Regulators are looking more at majority minority areas more-so than LMI - so get out your ECOA/FHA hat rather than CRA.

Pricing - document the differences in pricing due to risk! Let your risk officer have facts and statistics why a range of 680- 719 is more costly to service and higher potential charge off risk than a 720+.

Those are starters Identify ranges, terms, etc. and have documentation WHY there are differences in guidelines, rates and terms. Oh, with the loan amounts, besides of race and ethnicity minorities, also think of senior citizens downsizing.