The regulatory world in which financial companies operate is a vast sea of uncertainty that is seemingly in a constant state of churn. Although the laws and regulations themselves are not necessarily constantly changing, regulatory interpretation and shifting priorities, coupled with bifurcated and shifting agendas, create a sort of organized chaos. This makes compliance difficult, […]
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In recent posts, we have focused on redlining as one of the more prominent fair lending risks that institutions are facing today. The agencies have clearly made redlining a top priority, and recent fair lending enforcement actions have confirmed this. There is, however, more to the fair lending risk management story. The Many Facets of […]
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As lenders face increasing scrutiny from the regulatory and enforcement agencies with regard to fair lending in general, and redlining in particular, institutions are searching for ways to mitigate these risks. Why Correcting a Problem is So Hard Fair lending risk management now demands a data-centered strategy, as the focal point of a redlining examination, […]
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In our previous post on the topic of redlining, we discussed how redlining is an issue that can have serious consequences for banks that do not adequately manage these risks. However, detecting and correcting redlining issues can be complex and nuanced, which is why it’s important to be proactive in addressing these and other fair […]
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Financial institutions are under constant and increasing scrutiny from regulators to manage fair lending risk and ensure compliance with fair lending laws. In this context, conducting fair lending risk assessments is paramount for risk managers who are aiming to not only meet legal requirements, but also promote positive customer outcomes and avoid appearances of practices […]
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You know the importance of ensuring compliance with fair lending regulations. But have you considered the dangers of redlining specifically and completely? Redlining Defined Redlining is the practice of denying or limiting financial services to certain neighborhoods or areas, often based on factors such as race, ethnicity, or income level. While it is illegal, redlining […]
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Overview Earlier this month, there was a major development that could prove to be very significant in regard to fair lending. On September 1st, the CFPB released its proposed rule regarding small business lending data collection. The rule, mandated under the Dodd-Frank Act, and, if finalized and implemented, will require lenders to collect and report […]
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With respect to potential fair lending issues, redlining has remained a significant focus during regulatory examinations for a number of years. There are a number of critical pressure points that should accompany an institution’s self-evaluation of redlining risk. These points are broad and range from marketing efforts, products, branch locations, delineation of assessment and market […]
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In previous posts (see The Fair Lending Risk of Good Intentions) we have discussed fair lending risks associated with certain well-intended practices. In an effort to avoid fair lending risks, institutions may find it tempting to have practices that either favor protected classes or policies that eliminate any variation in pricing or decisioning in an […]
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2020? Yes, 2020. With the bizarre nature of last year, it is easy to overlook some of the year’s significance. One is that 2020 was a Decennial Census year, with the population of the U.S. recounted. It is never too early to think about this as there will likely be changes that will affect those […]
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