Discrimination can be obvious, subtle or unintended. Charges of discrimination can come from any direction. Risk comes in the form of penalties, regulatory enforcement actions, civil liability, or damage to a bank's reputation, to mention a few. The best defense to these threats and risks is developing and maintaining a sound fair lending compliance management system.
Over the years Fair Lending violations have led to consent decrees that include:
• Significant civil monetary penalties;
• Reimbursement to borrowers; and
• Burdensome remedial action to prevent further violations.
Upon completion of this program, participants understand:
Fair lending concepts;
Laws and regulations;
Bases of discrimination;
Types of discrimination;
How to build and maintain a fair lending compliance management system, including policies and procedures;
How to conduct a fair lending risk assessment;
Evaluating inherent and residual risk;
For various loan products (commercial, real estate, consumer, etc.);
For various aspects of the process (application, underwriting, pricing, advertising, collection);
How to mitigate fair lending risk:
Reviewing policies and procedures for fair lending problems and eliminating those concerns;
Training - Who, How, When, and What
HMDA , CRA and Section 1071 data;
Statistical analysis (regression analysis, etc.);
When is such analysis suggested;
How to conduct the analysis;
Should you do it yourself or contract the service;
The impact of the Supreme Court's ruling on discrimination based on gender identity or sexual orientation;
The CFPB’s interpretative rule on Equal Credit Opportunity (Regulation B); Discrimination based on the Bases of Sexual Orientation and Gender Identity;
Fair lending enforcement actions;
Expansion of Regulation B to include data collection on loans to minority-owned businesses, women-owned businesses, and small businesses.
Kimberly Boatwright is EVP and Director of Risk and Compliance at Compliance Resource, LLC and has more than a two decades of experience working in the financial services industry. Ms. Boatwright is a well-regarded financial industry risk and compliance professional with a strong background in program development and implementation. She is a thought leader who specializes in Fair Lending, Anti-Money Laundering, OFAC and consumer compliance. During her career she has worked for and consulted with all types of financial institutions helping to establish and evolve compliance and risk programs. She is a frequent public speaker, trainer, and author on compliance and risk management topics. Kimberly is a Certified Regulatory Compliance Manager and a Certified Anti-Money Laundering Specialist.
Advertising,Audit and Internal Controls,Compliance,Compliance Management and Auditing,Fair Lending, ECOA,Lending,Lending: Administration, Compliance and Operations,Marketing and Sales,Real Estate Lending,Regulation Z: Truth in Lending,Risk Management