|
An affordable alternative to
staffing an extensive internal compliance program.
Compliance Services,
Inc.
PO Box 237
Orting, WA 98360
(253)756-5767 compliserv@aol.com
ccook14@aol.com
CSI Georgia
35 Roanoke Avenue NE
Atlanta, GA 30305
(404)266-0430
ljoddo@bellsouth.net
|
|
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:
- Selecting a target group from a prohibited basis category to test for
differential treatment that may be discriminatory.
-
Selecting a comparison control group of applicants different from the
target group to determine the level of equal treatment.
-
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.
-
Performing a comparative analysis of loan files to identify any disparate
treatment or exceptions to your institution's lending policies or practices.
-
Comparing applications from the target group and the control group to
determine differences in treatment of the applicants.
-
Conducting a review of the institution's advertising records,
fair lending training records, and Board approved policies, as applicable to
fair lending compliance.
|
