As you already know fair lending is a major industry hot button. This point was mentioned time and time again at the ABA Conference I attended earlier this year. Here is what I heard from the trenches. Everything you do is being reviewed by examiners from a fair lending perspective. For example:
- When an examiner is reviewing a file for the new RESPA and TILA requirements, they’re also looking for fair lending issues.
- When an examiner reviews your website for advertising compliance, they’re looking for fair lending issues.
- When an examiner is reviewing your lobby signage, they’re looking for fair lending issues.
The point to all this is that nothing is off limits. Fair lending risk is present everywhere, make sure you address it before examiners arrive.