Fintech relationships can help banks expand their credit reach to markets that they would otherwise struggle to access. However, new risks emerge when entering into these new markets through a delegated third-party relationship. One of these key risks is fair lending. Banks and their fintech partners are expected to comply with the Equal Credit Opportunity Act (ECOA) and, in general, lend in a fair and equitable manner to all people.

Asurity Advisors assigned a team of fair lending experts to engage with the client’s fair lending staff and leadership. Through document reviews, interviews, and walkthroughs, the Asurity Advisors team became fully immersed in the client’s approach to fair lending compliance and then applied those learnings against regulatory requirements and industry best practices. Asurity Advisors recommended several enhancements to the fair lending program, rooted in regulatory requirements and expectations. Asurity Advisors developed a list of findings, observations, and recommendations for the client to consider and incorporated these into a comprehensive report. At the end of the engagement, the fintech and their bank partners had reasonable assurance as to the adequacy of the FLCMS and insight into areas in which it could improve.