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#626107 - 10/18/06 02:51 PM Fair Lending Assessment for Non-HMDA Reporter
A Goodin Offline
New Poster
Joined: Jun 2006
Posts: 8
East Tennessee
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.

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Lending Compliance
#626108 - 10/18/06 03:03 PM Re: Fair Lending Assessment for Non-HMDA Reporter
Bagweaver Offline
Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
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.

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#626109 - 10/18/06 06:37 PM Re: Fair Lending Assessment for Non-HMDA Reporter
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,285
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.
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

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