Has anyone undergone one lately? My search for fair lending nightmares (used in training) have come up with not a whole lot since the early 2000. It doesn't seem to be the hot issue that it once was and it doesn't appear that CRA challenges are prevalent in light of the sunshine provisions. Does anyone agree that the emphasis on Fair Lending from the 1990's has dimmed? I'm not saying it's not important, but seems to have perspective now vs. then.

We're OTS regulated, and when they were in earlier this year, they looked at my latest fair lending review and didn't go further. Now I complete an extensive review following their procedures with very complete workpapers (hoping they'd use my review only) so they had lots of information to look at. They were satisfied with my review.

I'd rather stay on top of things than wait for this to become a "hot" issue again. My lenders have a tendency to not document as they should.

Thanks. It's the same with me. The mortgage loan problems currently in evidence nationally may stir it up again, but for now, it does not appear that discrimination resulted in loans that should never have been made!!! Doesn't that sounds strange?

OTS has told us that the next exam will focus on Fair Lending. It is one of the 4 HOT buttons for the next exam. The examiner said they are BSA/AML/CIP; Fair Lending, Flood, and Compliance Management.

OTS Southeast Region is requiring its institutions to have recent Fair Lending exams. If you don't have one on file, you will as it will be recommended in your report.

OTS Southeast Region is requiring its institutions to have recent Fair Lending exams. If you don't have one on file, you will as it will be recommended in your report.

Ditto Nikita on the OTS SE Region REQUIRING annual Fair Lending Audits.

Padric, have you seen some of these cases involving the U.S. Dept. of Justice?

The following link will take you to a case involving race and national origin.
http://www.usdoj.gov/crt/housing/documents/centier_pr.pdf

The following link will take you to a case involving a sexual harassment case filed under ECOA.
http://www.usdoj.gov/crt/housing/documents/1st_nationalbank_pr.html

The following link will take you to a case involving marital status discrimination.
http://www.usdoj.gov/crt/housing/documents/compass_pr.pdf

The following link will take you to a case involving car dealerships.

http://www.usdoj.gov/opa/pr/2007/August/07_crt_639.html

The following link will take you to information involving the NY State Attorney General and Countrywide.

http://www.oag.state.ny.us/press/2006/dec/dec05a_06.html

We are regulated by the OTS. During our 2006 exam, they asked us to conduct a fair lending exam using the FFIEC fair lending exam procedures. They said we didn't have to do them all by the next exam. We agreed to do a comparative file analysis for the next exam. When they came in for the 2007 exam, they reviewed what we did and were satisfied. We agreed to do a pricing review before our 2008 exam.

Related Question -
Does everyone share their Fair Lending Exams with the regulators?

As there is specific guidance stating there is no requirement to do so aren't we risking setting ourselves up (through voluntarily giving them the report) when we do or establishing an automatic red flag if one year we opt to keep it private?

I've always shared my fair lending reviews with my regulators - OCC and Fed at my former bank and the OTS at my current bank. I'd rather they look at the files in my review and possibly choose a few more rather than pull a full sample on their own. So far, I've never had a problem.