The October 4, 2016 Interagency Fair Lending Hot Topics included the sessions listed below. It looks like "redlining" will be a concern by all bank regulators in 2017.
- CFPB Mortgage Updates - Focus on Bancorp South enforcement action for redlining and use of "paired testers". Also included overview of 2018 HMDA rules that will add MORE data for fair lending analysis
- NEW Compliance & Community Affairs Business Unit - OCC - includes "heightened" focus on Fair Lending
- Redlining Risk - Federal Reserve
- Redlining - A Bank's Reasonably Expected Market Area, FDIC
- Redlining - Enforcement Section, Department of Justice
- New HMDA rules will go into effect in 2018, now is the time to start updating the HMDA data collection process. How will the proposed additional HMDA data fields impact fair lending?
- The FDIC has introduced a new acronym into Fair Lending AND CRA compliance -the REMA - "reasonably expected market area". Learn the "new normal" of the SEVEN FACTORS used to define a REMA and tips to prove compliance. Review of the 10/27/2016 FDIC presentation on "Determining the Reasonable Expected Market Are for Redlining Analysis". The FDIC is also focused on THIRD PARTY relationships that may impact fair lending.
- What are the fundamentals of Fair Lending, including best practices for inquiries, loan interviews, application processing, and documenting denials?
- Compensation issues - recent headlines about the abuses of Wells Fargo and pressure to perform will bring more focus to this area.
- What should you know about the interagency Fair Lending examination procedures used by the CFPB, OCC, FDIC, and Federal Reserve?
- How can an effective internal Fair Lending review help detect problems before the examiners arrive? How would your bank be viewed by "paired testers"?
- What should your internal Fair Lending training sessions cover? Who needs the training?
Who Should Attend?
Both experienced and new Compliance Officers, Auditors, Lenders, Loan Operations, Risk Managers, and Senior Management. Requirements for small and large financial institutions are covered. Links will be provided for the CFPB, OCC, Federal Reserve, and NCUA exam procedures.
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