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“Small daily improvements over time lead to stunning results.  Why?  Because consistency is the mother of mastery.  And incremental improvements are the father of exceptionalism.”-Robin Sharma

Achieving fair lending nirvana in your company policies and practices takes dedication and time; which are rare commodities.  However, it does not need to take over your life as there are incremental improvements that your company can make today, which are easy, and achieve great results.  These baby steps are a great way to “dip your toes” into the fair lending waters, if this issue has not been on your compliance radar screen.  The CFPB and the other prudential regulators have made it clear that fair lending is one of their highest initiatives and therefore, it should be yours as well.

A great Fair Lending program does not happen overnight, but it does need to start somewhere.  When I speak to many compliance officers they seemed frustrated that they just can’t get the fair lending message through to the executive decision makers.  They cite articles, settlements, litigation and any other sort of evidence that they can find, in order to express how important the regulators take fair lending.  These professionals know that preparing for an exam can be taxing even if you do have your act together, so when you don’t it is a true nightmare for all.

For some companies, this task is easier than for others.  After all, if you are working in a bank environment, then it is likely that fair lending is always an agenda item at the board meetings.  However, if you work in a mortgage banking environment, it may seem like science fiction to your executive team because they are not used to this oversight.  In fact, many times I hear about mortgage bankers hiring compliance personnel from banks, only to have those people get frustrated and leave the mortgage banker after a few months, because fair lending regulation was not taken seriously.  Yet to be fair, even banks haven’t quite perfected the very complex world of fair lending.

When I studied at Purdue University, School of Engineering for my Lean Six Sigma Black Belt, I did it because my goal was to figure out ways to improve the lender’s workflow in combination with all of the regulation that we now have.  This workflow needed to pump up their bottom line, satisfy the client and appease the regulators.  This is no small task as most of you know.  We all know that companies which are run efficiently have less problems, happier consumers, lower employee attrition and make more money.

What worked 10 years ago in our industry no longer does, because of the regulatory changes.  This is the first mind shift we all need to adopt.  If we don’t adapt our business strategies, we will stand by and let those who innovate with the regulations versus resist the regulations, steal our business.  Rome wasn’t built in a day, and it is likely that you will continue to work on your strategies for years. The regulators, however, want to see that you are actively giving it your best shot.

You will not want to miss this series if you are into simplicity, and getting things done correctly without a lot of stress.  With each post, I’m going to introduce a “quick fix”, incremental improvement that will help you build a solid fair lending program.  The solution will be something you can actively do that week to nip away at the bigger picture, along with how to document what you are doing for the regulators, and facilitate change if you need to.  This 10-part series starts on Wednesday!  Be sure to tell your friends about this blog, so they don’t miss out on this helpful information!

Tammy Butler, Master CMB

Author Tammy Butler, Master CMB

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