With the recent Supreme Court Ruling upholding Disparate Impact, today’s lenders are required to take a strong look at their Fair Lending Analysis, by strongly monitoring their lending in well -served vs. under-served markets, product diversification, pricing parity and pricing exceptions. All of this needs to be done in a real time fashion to demonstrate proper controls to an examiner.
For banks, this is going to require updated technology solutions that go beyond static data set analysis.
For Mortgage Bankers, this is going to require an entirely new approach to your best practices for monitoring fair lending, guarding consumer interests and demonstrating diversity to an examiner. Mortgage lenders never worried about these issues before, but they are here to stay now.
In order to assist you in this process, I’ve written a new Whitepaper titled “How Does Disparate Impact Affect Mortgage Bankers & What You Can Do to Protect Your Company” which can be downloaded below.
As you know, I am not a big proponent of putting out a problem without offering a practical and easy to understand solution, so I’ve also included a “Disparate Impact Readiness Checklist” to assist you in the discussions, which you will enviably need to have in your company.
There are easy & affordable solutions for making this process workable so make sure you are:
1. Discussing the latest offerings at OB with your Account Manager or Business Development Manager regarding what is available and how it can apply to your business.
2. Keep your integration and software upgrades up to date. Otherwise, you miss out on important workflow functionality necessary to demonstrate compliance during these rapidly changing times.
3. Don’t hesitate to reach out to me to discuss this topic. I’m here as your resource and I am happy to share best practices for dealing with this new scrutiny.
Please post your thoughts or questions!