When you have a Fair Lending exam, there really should be no surprises. The FFIEC, FDIC, and CFPB have all published their fair lending examination procedures, which spells out what they are going to look at. So, in reality, it’s like an open-book test.
Jerod explains more in the video.
Page 14, the Exam Procedures: This is an open-book test. We know exactly what they're going to ask and what it will be in relationship to. You can see there are different versions of it. This is the FFIEC Interagency Exam Procedures letter B. Letter C is the scoping and conclusions memorandum by the FDIC. And I don't care that you're not FDIC regulated. The best of these three is the letter C. I would go ahead and circle letter C and say even if you're not FDIC regulated. This is the most up-to-date and, in my opinion, provides the best questions to prepare you and your teams to get ready for a fair lending examination. And you can see the CFPBs are at the bottom of the page, as well.
Published
2022/01/10