Understand Where Your Data and Programs Meet to Control Risk

Published in the April 19, 2019 issue of Compliance Action, this article addresses lessons learned from past fair lending consent orders. Adequate fair lending risk management requires not only awareness of potential fair lending risk, but an understanding of how that risk is affected by the institution’s programs and how those programs are executed. Only then can adequate controls be developed to mitigate the risk and monitoring be developed to gauge the effectiveness of those controls.