Skip to Main Content
Read More Read More Read More Read More Read More Read More
Subscribe to our content or get in touch with us today Subscribe Contact Us
On Friday February 20th, 2015, the NCUA shared some insights in regards to how the regulators approach Fair Lending. Here are some common Fair Lending Exam Triggers and Best Practices. It is “HMDA Week” for many in compliance. That means that you may be reviewing your HMDA data. In honor of "HMDA Week," we've summarized these fair lending best practices and common tripwires, drawn from the NCUA's recent fair lending webinar. In our experience, best practices and common errors are universal across the regulators. So even though these best practices are derived from the NCUA's recent webinar, we believe you can confidently apply these tips regardless of your regulator.Fair Lending Exam TriggersAre you ripe for a detailed fair lending exam? The NCUA determines which organization will receive a fair lending exam based on the following triggers:
This list of “exam triggers” are similar to what we see from other regulators when it comes to more in-depth fair lending compliance exams. Here is a quick video outlining these exam triggers. Fair Lending Compliance Best PracticesHere are four best practices that your organization may want to consider:
These elements of a strong compliance management system as outlined by the NCUA are aligned with recent guidance from the CFPB. The CFPB, in April of 2014, published the following list of elements in a well-developed CMS (click here):
TRUPOINT Viewpoint: The regulators continue to provide more specific guidance regarding the fair lending best practices. They've clearly stated that they are planning to analyze your data to determine if you are an outlier (e.g. denial rates, rate spread loans, withdrawals). The CFPB is "committed to using data-driven analysis" to identify and evaluate financial institutions. Your data - as well as and your complaints, compliance history, etc. - may lead to an in-depth examination of your fair lending compliance management system. Are you following best practices? Is your data a fair lending tripwire? As many of you know, HMDA data is due on March 2nd. March 3rd is the starting line for “analysis season.” After you submit your data, the regulators will begin reviewing it, and composing a story about your institution's compliance based on their analysis. Put yourself in a strong position to present, explain, and share your story by analyzing and reviewing your data proactively. At TRUPOINT Partners, we help more than 500 organizations analyze and interpret their HMDA data. You can proceed with confidence with TRUPOINT Partners. Get free sample reports: Read More: (Click to view the presentation.) |