2014 ABA RCC: Lessons Learned from Recent Fair Lending Cases

This is the fifth installment in a series of blogs covering the sessions I attended at this year’s American Banker’s Jerod11Association (ABA) Regulatory Compliance Conference (RCC) in New Orleans.

Fair lending is the hottest compliance topic in the industry and it’s likely at the very top of bank management and CEO paranoia (although UDAAP is right there too)! It’s safe to say Fair Lending concerns are not going to die anytime soon. Here are a few of the takeaways from this session:

• Any lender discretion (loan policy and/or procedure exceptions) must be monitored and controlled.

• Those involved in the indirect lending arena MUST monitor dealer markup.

• Disability income documentation requirements (just Google it).

• Loan steering – Make certain the consumer receives the best deal for them regardless of the channel in which the application was received (i.e., branch location, online, mail, etc.)

Jerod Moyer

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