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There are more ways to fall into fair lending trouble than ever and more enforcers watching to see if you do.
The Department of Justice’s fair lending unit, on the job since 2010, has identified residential finance as a main focus. The DOJ has teamed up with the Department of Housing and Urban Development, bank regulators and the Consumer Financial Protection Bureau to ramp up its anti-discrimination efforts, imposing enforcement actions and significant monetary penalties.
The CFPB is keeping an eagle eye out for fair lending violations, scouring Home Mortgage Disclosure Act data for patterns of discrimination and undertaking targeted Equal Credit Opportunity Act reviews and deeper fair lending analysis in supervisory exams and investigations. It is pursuing its own remedies in some cases and referring others to the DOJ.
Both the DOJ and the CFPB are focused on effect, meaning there is no safe harbor available just because one didn’t intend to discriminate.
Get the full picture of current fair lending exam and enforcement risks and what you can do to lessen your exposure in Inside Mortgage Finance’s Guide to Fair Lending Compliance: 2nd Edition.
Partial Table of Contents
Fair Lending Issues
+ Types of Discrimination
+ Prohibited Practices
+ Redlining Issues
+ Defining a Lender’s Peers
+ Underwriting Risk Factors
+ Pricing Risk Factors
+ Marketing Risk Factors
+ Opportunities to Improve
+ Insight from Consumer Advocates, Regulators
The CFPB and Fair Lending
+ ECOA Reviews
+ Underwriting Reviews
+ Varying File Selection Methods
+ Managing Underwriting Risks
+ Fair Lending Risk Under TRID and HMDA
+ Non-QM Lending
Fair Lending Risk Assessment
+ Organizing the Risk Assessment
+ Controls to Mitigate Risk
+ Targeted Analysis
Recent Fair Lending Actions
+ DOJ Settlement with Evolve Bank & Trust
+ CFPB, DOJ Settlement with Hudson City
+ Miami Lawsuits Against Big Banks
+ Cities’ Predatory Lending Charges Against Wells
+ Lawsuit Against Fannie Mae’s REO Practices
+ Lenders Prevail Against Novel Charges