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.

Examination scope

The Interagency Guidelines for Self-Assessment requires a comparative review of approved versus marginally denied borrowers that have similar characteristics, i.e., “closely matched pairs”.

Our proprietary software produces a series of reports that help you uncover disparate pricing and other areas of weakness, 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

File documents are reviewed to assess whether or not the borrower was offered less favorable loan terms, or not presented a full range of options. Documentation review will indicate whether appraisers or other service providers were influenced or the underwriter explained departures from credit standards. Our reviews cover an assessment of reasonable ability to repay and, for refinances, net tangible benefit.

An impartial approach

A fair lending evaluation should be completed in an area outside of mortgage lending production and by compliance specialists who understand testing criteria such as the control versus prohibitive ratio.

Our services, provided by trained analysts at Bankers Advisory, a CliftonLarsonAllen division, offer two key advantages:

  1. We have two decades of direct experience in completing assessments under the interagency guideline.
  2. Our testing services are neutral and impartial.

Fair lending services for financial institutions

  • 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 and consumer handouts
  • Review of state-level compliance disclosures
  • Review of federal and Dodd-Frank Act disclosures

Additional Bankers Advisory services

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting, investment advice or opinion provided by CliftonLarsonAllen LLP (CliftonLarsonAllen) to the reader. Neither Bankers Advisory nor CliftonLarsenAllen is licensed to practice law, nor does either entity practice law. The information contained herein is for general guidance purposes and not a substitute for compliance obligations. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader’s specific circumstances or needs, and may require consultation with counsel if any action is to be contemplated. The reader should contact his or her CliftonLarsonAllen or other professional prior to taking any action based upon this information. CliftonLarsonAllen assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.