Yesterday I wrote about the 10 Triggers for Fair Lending. Today we start to build those compliance management systems into your workflow by getting organized. When I approach a project, I like to break it down into bite sized chunks with the big picture in mind. From there I am able to work out the details, and pass it to the Project Manager who can coordinate efforts to accomplish process changes.
As a Refresher, here are the 10 Fair Lending Triggers.
- Pricing Disparity
- Pricing Exceptions
- Underwriting Disparity
- Underwriting Exceptions
- Marketing Disparity & UDAAP Violations
- Disparate Impact
- Data Integrity
- Client Interaction & Client Parity
Next, start a spreadsheet and put these triggers across the top as headers. Make sure you leave a column for “positions”. LinkedIn and WordPress have few formatting options so I cannot demonstrate this visually, however, the book at the user conference will have a sample spreadsheet.
Down the left column of the spreadsheet, list every position in your company that handles or touches a file from origination to closing. This includes Marketing. Although they do not touch a file, they do produce information for the client.
Now, working through each position, check any “trigger” area this position may have. For instance, for the position “underwriter” I would check “underwriting disparity”, “underwriting exceptions”, “data integrity” and “client interaction & client parity”.
Do this for each position that interfaces or makes decisions on with a consumer. Depending on the size of your company you might want to group like positions together to make life a little easier.
This process lays the groundwork for our next steps which is building the workflow, and compliance management system around it.
Stay Tuned! Next we will begin to build your system incorporating this worksheet into the 3 areas of a compliance management system; training, policies & procedures and monitoring as all positions will require those!