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#314449 - 02/09/05 06:45 PM Fair lending audit responses *DELETED*
Love those Regs Offline
Gold Star
Joined: Apr 2002
Posts: 296
Southern State
Post deleted by Karen Sue
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Opinions are mine and subject to change frequently

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Lending Compliance
#314450 - 02/09/05 07:10 PM Re: Fair lending audit responses
Anonymous
Unregistered

Karen Sue,

Can you find a similarly situated loan for a member of a prohibited basis goup? Or in lay terms, have any loans been made to a female that had to go to committee? What was the reason for making loan?

What does lending policy say about credit applications if they don't meet underwriting standards? Are they automatically sent to committee?

When working for a smaller institution we instituted a peer review of all declined loans. A second set of eyes cannot hurt.

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#314451 - 02/09/05 08:13 PM Re: Fair lending audit responses
Matt1 Offline
100 Club
Matt1
Joined: Apr 2003
Posts: 129
Here's my two cents: watch out for loans where the CEO knows the applicant. As a former examiner, those were really difficult to distinguish from the loans to a protected member with better credentials. More often than not, Bank CEOs are white men -- and their friends are white men.

If I were in your shoes, I would bring the two or three stronger female loans to the CEO (or to your manager) and compare them line-by-line with the approved male. That's what an examiner is going to do -- and that's what you get paid to do. Watch the loan-to-friend scenario.

I'm not saying a bank cannot give a break to loyal customers. But, when you consider account relationships and length of relationships and the numerous underwriting guidelines and you still find that females were denied and had better overall credentials than males, there's a problem.

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