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#1369987 - 04/06/10 07:08 PM Fair lending risk assessment!!???
Trees Offline
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Joined: Apr 2005
Posts: 4,013
I am seeing a lot of ink being spent on the subject of Fair Lending risk assessments.

Has there been some directive from the Feds that we do yet another separate risk assessment?? Or, is this the new flavor of the week??

We had consumer here in 2009. No issues and no mention of a risk assessment.

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Lending Compliance
#1370204 - 04/07/10 12:37 AM Re: Fair lending risk assessment!!??? Trees
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,224
Galveston, TX
If you want to prove that you don't have any fair lending concerns to the regulators when they ask, how else are you going to prove it? I would much rather put my own together than let them do one.......
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#1370311 - 04/07/10 01:40 PM Re: Fair lending risk assessment!!??? rlcarey
Trees Offline
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Joined: Apr 2005
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Well, we have a loan policy/procedures which assist in providing some consistency in the application review process, we have fair lending training, second review of declines, etc. I was looking for some guidance as to how people are doing the risk assessment. For example, list the potential problem and then the controls, and then rank the potential for the problem, etc. etc. or are poeple doing more and more comp. file reviews? All this is prompted by the ABA's 2 session Fair lending webinar....that includes regression analysis. We are a community bank. I haven't dealt with stats since I took the course eons ago....I'm looking for alternatives to satisfy the examiners.

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#1370611 - 04/07/10 05:20 PM Re: Fair lending risk assessment!!??? Trees
Lissa P. Offline
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Joined: Oct 2003
Posts: 474
Texas, USA
There is a lot of guidance out there if you have time to research... I just completed ours for 2010. I found a lot of help in the "Fair Lending Risk Assessment Primer- The Regulator's Perspective" from ABA Bank Compliance January/February 2008.

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#1371005 - 04/07/10 11:00 PM Re: Fair lending risk assessment!!??? Lissa P.
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,224
Galveston, TX
I think the risk assessment in the examination guidelines should also give you a good start. Might as well look at it like the regulators do.
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