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Almost 2021: Year-in review perspective of HMDA, Fair Lending, and CRA developments
As we ring in the new year, it is helpful to recap what has happened in 2020 on three different fronts: HMDA, fair lending, and CRA. I count eight important developments. These are listed in no particular order below: 1. Modifications to the 2020 and 2021 HMDA Filing...
A Holistic View of Fair Lending: The Loan Lifecycle
We are pleased to post a blog written by a guest author. As a former examiner with the FDIC, Tory Haggerty has a lot to share and offers some practical advice on his view of fair lending monitoring and identifying hidden risks. He poses critical questions...
It’s All About Underwriting and Pricing Exceptions
One key component to any fair lending monitoring program is robust monitoring of underwriting and pricing exceptions. The Interagency Fair Lending Examinations Procedures indicate that institutions face increased fair lending risk if internal policies are vague with...