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...

How Well do You Really Know Your HMDA Peers?

Questionable HMDA annual income values can compromise the integrity of fair lending and Community Reinvestment Act (CRA) analysis. This field seems straightforward, right? The lender reports the “gross annual income relied on in making the credit decision”. The lender...