Interagency overdraft services consumer compliance discussion. The consumer financial protection bureau bureau, office of the comptroller of the currency occ, board of governors of the federal reserve system board, federal deposit. Comply fair lending is a robust software solution based on the ffiec federal financial institutions examination council and cfpb consumer financial protection bureau fair lending examination procedures and is the simplest and most cost effective way to monitor potential risk associated with lending performance. Compliance insights january 2020 protiviti united states. This overview provides a basic and abbreviated discussion of federal fair lending laws and regulations. Interagency statement on the use of alternative data in credit underwriting the board of governors of the federal reserve system, the consumer financial protection bureau, the federal deposit insurance corporation, the national credit union administration. The contents of this presentation are intended to provide you with a general understanding of the subject matter. Fair lending continues to be one of the highest risk areas for any creditor. With trupoint analytics fair lending analysis software and our compliance experts, we provide the insight you need. The folks from national penn bank, pa, have shared a fair lending training tool they find useful. The federal reserve discussed compliance management for consumer loans, specifically pricing discretion. Interagency policy statement on fair mortgage lending practices.
The federal financial institution regulatory agencies the agencies, in consultation with state financial regulators, issued a revised interagency statement encouraging financial institutions to work constructively with borrowers affected by covid19. Deficiencies can result in significant penalties, fines, and other enforcement actions. I have been researching fair lending software outside of wk wiz, as the cost seems to be prohibitive and we felt like the results werent concrete. However, it is not intended to provide legal, accounting, or other professional advice, and should not be relied on. Consolidated compliance manual pdf 18mb last updated. In october 20, we received an interagency statement on fair lending compliance and the abilitytorepay and the qualified mortgage standards rule, which provided guidance on qualified mortgage fair lending risks. In october 20, we received an interagency statement on fair lending compliance and the abilitytorepay and the qualified mortgage standards rule, which. Interagency statement on fair lending compliance and the ability. During this session, representatives from six federal agencies will discuss a variety of fair lending topics, including.
Apply to compliance officer, lending officer, senior compliance officer and more. The fdics consumer compliance examination manual manual is revised on an ongoing basis as rules, regulations, policies, and procedures change. Rata associates, the leading provider of hmdacra products and services to the lending compliance arena expanded into the fair lending market with the release of comply fair lending in 2004. Ecoa baseline basicsgetting to know your fair lending. The consumer financial protection bureau bureau, office of the comptroller of the currency occ, board of governors of the federal reserve system board, federal deposit insurance corporation fdic, and the national credit union administration ncua collectively, the. Regulatory compliance strategies for commercial lenders. Tara oxley, chief, fair lending and cra examinations, federal. Interagency statement on fair lending compliance and the abilitytorepay and qualified mortgage standards rule. Interagency statement on fair lending compliance and the abilitytorepay and qualified mortgage standards rule 20 fdic resources. Interagency statement on fair lending compliance and the.
Matthew nixon, program officer, office of consumer. Trupoint seems to have the more advanced analytics. It equips fair lending analysts with the tools needed to quickly and efficiently conduct evaluations that lead to effective analysis of risk management and lending practices. Guidance in the appendix to the interagency fair lending examination procedures provides details on how to obtain relevant information regarding such situations along with methods of evaluation, as appropriate. Though the fair lending laws and regulations do not specifically state that training is required, there is an expectation that it be provided.
In our december 2017 newsletter, we gave a summary of the november 16, 2017, outlook live webinar on 2017 interagency fair lending hot topics. This revised interagency statement clarifies the interaction between the march 22, 2020, interagency statement and section 40 of the cares act, temporary relief from troubled debt restructurings section 40, as well as the agencies views on consumer protection considerations. These are very well written and will suit the needs of many for initial fair lending training, or as a refresher. This is an excellent set of tools you may use for training. This guide is intended for use by a credit unions board of directors and management, compliance officers, and others having responsibility for fair lending compliance. Nov 22, 2017 the frb recently hosted a fair lending hot topics webinar in conjunction the doj, hud, cfpb, fdic, occ, and ncua. I have seen demos from trupoint and also questsoft fair lending magic. The checklist is not intended to be an absolute test of an institutions compliance management program. Equal credit opportunity and fair housing acts enforcement policy statement 1981 interagency statement on fair lending compliance. Fair lending best practices fair lending is more easily said than done.
Frb hosts 2017 interagency fair lending panel consumer. Federal financial institutions examination councils ffiec interagency fair. Fair lending supervision and enforcement providing oversight and enforcement of federal fair lending laws rulemaking working with fps office of regulations on fair lendingrelated rulemakings outreach promoting fair lending compliance, education, and reporting interagency coordination coordinating fair lending. The recent interagency statement does not identify new areas of concern or provide new or definitive guidance to financial institutions. Fair lending report 2016 we are committed to ensuring fair, equitable, and nondiscriminatory access to credit by finding and eliminating discriminatory lending practices, and also by encouraging lenders to maintain robust compliance management systems that reduce the chances of discrimination occurring in the first place. It is adapted from the interagency policy statement on fair lending issued in. Please join us for an interagency discussion of fair lending. Step two identify compliance program discrimination. The sole role of this fair lending regulation is to provide the availability of credit to all creditworthy applicants without regard to race, color, religion, national origin, sex, marital status or age. In this datacentric regulatory environment, you need to understand what your data says about you. Fair lending compliance resources national credit union. Fair lending wiz is a complete and automated fair lending management solution from wolters kluwer designed to provide robust analysis that allows you to easily identify potential risk and immediately take corrective action to remedy unfair lending practices. Interagency policy statement on fair mortgage lending. The ffiec has announced the release of core interagency fair lending examination procedures, which establish a uniform set of procedures to be used by each of the ffiec member agencies in their examinations for compliance with the broad, nondiscriminatory requirements of the equal credit opportunity act and the fair housing act.
The federal reserve is issuing the attached interagency statement on fair lending compliance and the abilitytorepay and qualified mortgage standards rule to clarify supervisory expectations regarding fair lending compliance and the abilitytorepay and qualified mortgage standards rule abilitytorepay rule, which implements provisions of the truth in lending act. The seven agencies discussed fair lending developments, including the revised hmda reporting requirements, compliance management for consumer loans, and various issues related to fair lending complaints, investigations, and enforcement. Fair lending magic automates compliance and fair lending risk analysis for all types of loans. Fair lending compliance training webinar 472016 gbq. Last, as a result of the financial services regulatory relief act of 2006, occ examiners may ask for the results and findings of bank performed selftests. Banking regulations compliance 2017 interagency fair lending.
The fed consumer affairs letter ca 15 on interagency. Step two identify compliance program discrimination risk factors. Fair lending report 2016 consumer financial protection bureau. Outlook live consumer compliance outlook federal reserve system. Addition of appendix o, the april 15, 1994, interagency statement, policy statement on discrimination in lending. Comply fair lending is a robust software solution based on the ffiec federal financial institutions examination counci and cfpb consumer financial.
It is adapted from the interagency policy statement on fair lending issued in march 1994. Five federal regulators, with hud noticeably absent, issued the first interagency guidance on the muchdebated intersection of fair lending enforcement and the abilitytorepay and qualified mortgage standards rule taking effect in january 2014. These resources provide guidance on how to comply with fair lending laws. Comply fair lending risk analysis software rata associates. The federal financial institutions regulatory agencies are issuing this statement to emphasize their concerns about fair treatment of applicants for mortgage loans and their continuing efforts to ensure such treatment. Interagency fair lending examination procedures ffiec.
Establish prudent policies with specific guidelines addressing fair lending considerations for application, underwriting, servicing and collection practices. Apply to compliance officer, lending officer, risk analyst and more. Federal register policy statement on discrimination in. Consumer compliance outlook outlook live archives 2019 fair lending interagency webinar. The interagency fair lending examination procedures contain multiple references to training and how it relates to fair lending compliance. Interagency fair lending examination procedures circulars.
Fair lending authority the federal reserve board supervises. Interagency statement on the use of alternative data in. Therefore, each creditor must understand the different types of fair lending violations that could be cited during a fair lending audit or compliance examination. Even more recently, the use of alternative data in the underwriting process was identified as a potential fair lending risk in the occs spring 2019 semiannual risk perspective. Equal credit opportunity act 1974 ecoa the federal reserve and the ftc enforce this law. Compliance tech web based fair lending software for. This discussion will focus on fair lending risks and compliance. Policy statement on discrimination in lending april 15, 1994 155. The public inspection page may also include documents scheduled for later issues, at the request of the issuing agency. Comply fair lending is a robust software solution based on the ffiec. Fair lending is an issue that continues to be a hot topic and this webinar gave some good insights. This guide is intended for use by a credit unions board of directors and management. Matthew nixon, program officer,office of consumer financial. The other hmda regulators issued similar statements.
172 578 465 430 721 567 267 36 312 190 386 1234 1007 526 325 665 304 389 1308 422 1524 352 23 617 881 343 51 1308 1139 278 1121 1085 829 1119 1411 1436 176 783