Fair lending compliance is an important component of a financial institution’s overall CMS irrespective of size and complexity. Although all banking regulators evaluate fair lending compliance management systems and performance, each has slightly different expectations and areas of emphasis.

Asurity Advisors worked closely with the bank to obtain governance documentation and monitoring results related to the bank’s fair lending program. Following the documentation review, Asurity Advisors held one-on-one interviews and walkthroughs with key stakeholders to get a firm understanding of the bank’s practices. Following the review, Asurity Advisors discussed the identified gaps and associated recommendations for the bank’s consideration.
With respect to redlining analytics, Asurity Advisors used Home Mortgage Disclosure Act (“HMDA”) and key fair lending data provided by the bank to perform customized analyses of the redlining risks that existed within their lending footprint/markets over a multi-year period. For this analysis, Asurity Advisors conducted the reviews using the same methodology and peer groups as the OCC. Asurity Advisors carefully analyzed the results, recommended approaches to improve performance, and explained the redlining analysis and risks to various internal and external stakeholders.