Fair Lending for Financial Institutions

The Interagency Guidelines for Self-Assessment were released in 1994. Since then, Bankers Advisory has completed tens of thousands of side-by-side assessments based on the recommended procedures, now adopted by the CFPB.

What’s on your mind

  • Regulators’ continual focus on fair lending compliance
  • Completing a comparative file review of approved versus marginally denied loans files, as describe in the Interagency Guidelines for Self-Assessment
  • Understanding and utilizing your loan data to demonstrate your institution’s commitment to fair lending

A unique approach

A fair lending evaluation should be completed in an area outside of mortgage lending production and by compliance consultants who understand testing criteria such as the control versus prohibitive ratio. CLA Bank Advisors has two decades of direct experience in completing assessments under the interagency guidelines providing neutral and impartial testing services.

Our proprietary software produces a series of reports that help you uncover disparate pricing and ascertain the relationship between loan features and other loan file characteristics, including:

  • Similarly situated borrowers by property and transaction
  • Similarly situated borrowers by underwriting risk and credit score
  • Originator service standards
  • Compliance and service standards by processor
  • Compliance and service standards by underwriter

Fair lending services

  • Side by side file reviews of closed loans
  • Reviews of closed versus denied loans
  • Review of fair lending policy and procedure
  • Review of loan applications
  • Review of state-level compliance disclosures
  • Review of federal compliance disclosures