“Tell me the facts and I’ll learn. Tell me the truth and I’ll believe. But tell me a story and it will live in my heart forever.” An old Native American proverb
Everybody likes a great story and examiners are no exception. One of the worst ways you can tell your companies’ fair lending story is to let the examiners find out everything on their own and make up their own story! Yikes! Those who have mastered the fair lending story of their company are far less stressed and have better results because they are prepared.
Quick Hit #10-Build Your Fair Lending Story
Here are some tips to build your company Story:
- Talk about the fair lending culture at your company from the front line staff all the way to the board of directors. Accentuate how important being a fair and responsible lender is, and how you are going to demonstrate how seriously the entire company takes this responsibility!
- Next, go into the change management culture of your company. Tell the story of how your company handles and adapts to the ever-changing regulatory environment and modifies policy, practices and training as the requirements change.
- Become one with your company data! Whether it is the statistical analysis of your HMDA data, or data derived from other monitoring methodologies, no one should understand what it says better than the point person with the examiners.
- By now you have taken the time to get policies in place. Part of your story should be how strong those policies, practices and procedures are. You want to let the examiners know that the workflows that you present to them, follow the process of the person performing the function and that they have been checked against actual job performance.
- And how about those monitoring processes? They are great, right? Be sure to highlight how those monitoring processes work, and how they are so good you can pick up things before harm comes to the consumer. Not to mention if you do miss something it is picked up elsewhere, and the consumer is made whole again!
- How do you keep the board of directors or executive team in the fair lending loop? After all, the leaders of your company need to be well-versed in what is happening in their company to make proper decisions. Your communication and how they respond to fair lending monitoring and policy is part of that story.
- Discuss how your technology is part of the master plan, and how that is constantly adapting to assist in consumer protection, or streamline your fair lending monitoring.
- What are you monitoring methods? Why are they great and how do they help you monitor fair lending holistically?
- Training your staff in fair lending law is just the basics. Go further to discuss how each department receives the level of training necessary to ensure that all of your clients are treated consistently and fairly. If you do mystery shopping or contract someone that does, what does this data reveal? For those employees with problems, what is the remediation plan? Share the stories of those who are doing a great job and how it has impacted a consumer. Share the consumer story as an example!
- Discuss your complaint process and how quickly issues are detected, consumer concerns are addressed and how people/processes are adjusted to better serve the customer.
All of these suggestions help you build a story about a company that wants to do well and is trying hard to make great things happen for consumers. If you don’t tell your own story and let the examiners come up with their own stories based on their “findings”, then you do yourself and your company a disfavor. Of course, you can’t just make stuff up. Your story is not a work of fiction and should contain the truth whether good, bad or ugly. The good you are proud of, the bad is good because it helps to detect areas of improvement, and the ugly is in every business; but you root it out and fix it!
Although this is the last quick hit tip of our series, don’t worry! The content will continue to flow….
If you missed Quick Hits 1-9, you can find them on this blog.
