Recently, I was asked to perform a Fair Lending Audit for vehicle loans that were funded by our bank. Additionally, I was asked to perform an audit on our credit card portfolio. In the past, my review only covered mortgage loans. Is this a new requirement for lending products? Since they products are not reported under HMDA, what data would I pull?

This has been a tool used for many years. You would judgmentally select files based on the names, female, Hispanic, etc. or copies of photo IDs there for CIP. It isn't as strong or accurate as with files supported by GMI in the files.

You might also look at applications in high-minority census tracts versus low-minority census tracts.


Al