Fair Lending Best Practices Update!
The first quarter for collecting the NEW HMDA data has closed and now is the time to evaluate what this data says about your company practices.
Although the CFPB may not be as active as usual this year, Mulvaney has made it clear that Fair Lending Enforcement is still a high priority. I suspect that the 2018 data will be the catalyst for the bureau as the data scientist pours through it. The new data is already highly anticipated at the State and Consumer Advocacy level as they have both become more aggressive which is becoming problematic for many compliance departments. Instead of dealing with one regulator, they now have to deal with multi-state regulators on Fair Lending issues.
Here is a List of 3 Things You Should be Doing Now!
- Evaluate your 1st quarter data to see if you uncover any problematic trends in Pricing Disparity or Redlining concerns. These are generally the highest focus items of States and Advocacy Groups.
- Compare this information from 2017 and 2016. Are you improving in these areas or is there a noted difference?
- Diagnose and then plan to make some changes. Strategic changes now, will result in improved data as the year unfolds. Too many lenders wait until the year is over before they look at their data. By then, it’s too late.
If you see areas of concern or would like to be proactive, please consider Fair Lending Diversity to assist you with strategic plans and training. We help you make a big difference before it becomes too late. Our track record with large and small institutions helps your executive team make the right decisions. Contact Tammy Butler, Master CMB, LSS Black Belt at tammybutler@fairlendingdiversity.com.
