The OTS has made a recommendation that we perform an annual Fair Lending self-assessment. We are not HMDA reportable so much of the monitoring information is not readily available. How do other banks accomplish this self assessment? Any suggestions are appreciated.

We are a non-HMDA reporting, OTS regulated bank. I have my lenders complete a form on each application and the action taken on them including the information I need to complete a fair lending review. If you'll pm me with your email address, I'll forward a copy of the form.

Do you make real estate secured loans that are for the purchase or refinance of a consumer's primary residence? If so, then you should be collecting the data required by section 202.13(a) of Regulation B. You could then use this data to perform a fair lending analysis.