This is the first settlement I have seen where the use of proxy software is being cited as a way to prove disparity in pricing. I heard the rumors, but here is proof. $98 Million dollars later, and lots of attorney and consultants fees too, lead to a settlement where the CFPB had more data than the lender.
The data you will need to collect in today’s regulatory environment is getting intense. If you are still using technology that collects and monitors a fair lending issue on closed loans……..ask yourself will we be next and are we doing enough? Folks, this is like shooting ducks in a barrel to them!! The regulators know they have more sophisticated data gathering techniques and more up to date technology and they can spin it to win it for them. And the irony of it all is that there exists a quick and inexpensive fix, to out data the CFPB!
As the new year rolls out, resolve to change your old mindset that they way we used to do it is good enough. And by all means, if the only fair lending software that you use. looks at closed loan data, then the time could not be better to update your technique before your company becomes the next “settlement”.
To Read The Article Regarding the Settlement CLICK HERE!