Our Review Team incorporates a look at fair lending into our compliance reviews and includes any fair lending risk assessments, policies and procedures, complaints, training, HMDA analysis, and other related elements.
Interviews with lending staff are also conducted to ensure consistency in your processes. It’s common to get different answers to the same question, depending on who we talk to. A few areas where we see inconsistences include:
- Procedures and processes for requesting, documenting, and approving exceptions (loan terms, rate, etc.);
- Any approval process for waiving loan fees;
- Any processes for grossing up nontaxable income, including what forms of nontaxable income is to be grossed up and ensuring underwriting consistency among all lenders;
- Treatment of any types of income an institution won’t accept, such as bonuses, gambling, commissions, etc.; and,
- The credit report fees charged to married joint applicants when compared to unmarried joint applicants.
Published
2025/06/23
