We are in the initial stages of developing a Fair Lending program at my credit union. For smaller institutions, how do you pull data on non-HMDA loans to ensure fair lending? Since we do not collect gender, race, or ethnicity data on non-mortgage consumer loans, do you have a vendor that performs analysis based on surname and geo-coding? Or do you keep the analysis in house? I'm trying to figure out where to start. Many thanks!

We use a vendor software that will assign proxies.