#2279685 - 01/11/23 02:38 PM
Re: Mandatory Fair Lending Training
Anonymous
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Joined: Jun 2003
Posts: 7,659
Florida
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OCC (Training is mentioned 15 times in the Fair Lending Examination manual – some include
- Compliance program materials (particularly fair lending policies), training manuals, organization charts, as well as record keeping and any monitoring protocols, and internal controls.
- The bank’s own compliance program and previous examination findings may indicate system weaknesses that could lead to discrimination. Therefore, review information from examination work papers, bank records, and any available discussions with management representatives in sufficient detail to understand the organization, staffing, training, record keeping, auditing, and policies and procedures of the bank’s fair lending compliance systems.
- Compliance Risk Factors: C-7 Fair lending training is nonexistent or weak.
- NOTE: The items above are not compliance measures, but they are fundamental features of lending that tend to work against disparate treatment. b. Do training, application-processing aids, and other guidance correctly and adequately describe:
ô€† Prohibited bases under ECOA, Regulation B, and the FH Act? ô€† Other Regulation B substantive credit access requirements (e.g., spousal signatures, improper inquiries, protected income)?
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#2279860 - 01/16/23 03:49 PM
Re: Mandatory Fair Lending Training
Anonymous
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Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
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Andy and InFairness, agree 110%. That's what I was trying to allude to. Even if there are no fair lending issues, the bank will be potentially criticized, under the Compliance Management part. If there are fair lending issues, management cannot find a safe haven to hide, especially if training "could" have prevented the issue - it could be considered wilfull neglience, for the compliance officer, management and the board.
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