Fair Lending Review (side-by-side comparison)
We will review Fair Lending Related Regulations using a "side-by-side" comparative file analysis, which will be based upon an evaluation of the bank's fair lending policies, procedures and practices. After an initial assessment, either an "underwriting" or a "pricing" analysis will be preformed on samples of "target" and "control" group applications.
To accomplish this objective, we will review the bank's loan policies, underwriting guidelines and lending practices for the specific loan types selected by comparative analysis; review written complaints received by the bank alleging discrimination and management's responses to those complaints; review internal and external training activities regarding fair lending/nondiscrimination; and review denied and approved loan applications on the scoping guidelines and sample size criteria set forth by the regulatory authorities.