The fair lending compliance review conducted by CSI involves a comparative analysis of loan files and adverse action records to detect possible disparate treatment of minorities and other classes of protected loan applicants and borrowers.  

The focus of the review would be on residential mortgage loans because applications for these types of loans provide most of the monitoring information necessary to test for potential illegal discrimination. However, the review procedures would also include other types of loan applications and approvals, to the extent that information contained in the applications and files would allow for an effective fair lending compliance review.  

The steps involved in a fair lending compliance review include: 

1. Selecting a target group from a prohibited basis category to test for differential treatment that may be discriminatory.  
2. Selecting a comparison control group of applicants different from the target group to determine the level of equal treatment.  
3. Creating a sample of approved and denied applications of the appropriate size from each group to perform a comparative analysis to determine possible disparate treatment.  
4. Performing a comparative analysis of loan files to identify any disparate treatment or exceptions to your institution's lending policies or practices.  
5. Comparing applications from the target group and the control group to determine differences in treatment of the applicants.  
6. Conducting a review of the institution's advertising records, fair lending training records, and Board approved policies, as applicable to fair lending compliance.