We conducted a comprehensive evaluation of the bank’s fair lending compliance management system (FL CMS). The review included an assessment of board management and oversight, preventive and detective controls, complaint management, and third party risks. We provided recommendations to enhance the bank’s fair lending program and assisted in the revision of policies and procedures.
We provided fair lending advisory services to a national lender on development of statistical models designed to assess fair lending risk associated with marketing, underwriting, pricing, and loss mitigation. Assistance included the review of analytical results to assess and identify potential risk of disparate treatment, disparate impact and redlining. One of our fair lending practice… Read more »
Subsequent to a regulatory examination, we were engaged in an advisory role and in partnership with the bank’s legal counsel. Assistance included responses to examination requests for additional information, independent review of redlining risk and preparation for potential referral to the Department of Justice.
We were engaged to perform an audit of the bank’s fair lending compliance management system (FL CMS) in coordination with the internal audit department. The objective of the engagement was for CrossCheck to provide deeper expertise to the audit team. The scope of the audit included program governance, roles and responsibilities, policies, monitoring, and analytics. Line… Read more »
One of the pillars of an effective fair lending compliance management system (FL CMS) is the independent review or audit of the fair lending and responsible lending program. We assisted the company’s internal audit function in developing audit programs to assess the effectiveness of fair lending and Unfair, Deceptive or Abusive Acts or Practices (UDAAP)… Read more »
We have assisted numerous mortgage companies in validating the accuracy of Home Mortgage Disclosure Act (HMDA) data previously submitted or in preparation for an upcoming submission. Our approach to HMDA data errors and omissions testing integrates systemic data routines to identify conflicts between loan origination systems (LOS) and HMDA data. Identifying statistical anomalies or “red flags”… Read more »
We prepared a Community Reinvestment Act (CRA) performance evaluation for the bank in anticipation of its upcoming CRA examination. The performance evaluation is based on the regulatory CRA examination procedures and describes the bank’s efforts to meet the needs of the communities it serves. The engagement addressed the bank’s performance under the lending test, service test,… Read more »
We performed an analysis of the bank’s HMDA lending activity to identify 1) differences in levels of assistance based on the timing of decisions and final disposition of applications; 2) disparities in application outcomes including origination, denial, and non-decisioned applications; 3) pricing variances related to the frequency and magnitude of differences in APR and rate spread; 4)… Read more »
We assisted the bank in developing a Community Reinvestment Act (CRA) parity analysis to identify gaps in mortgage, small business, and small farm lending performance. Parity was established using owner occupied properties for mortgage and the distribution of businesses and farms for small business and small farm lending performance comparison. Distribution analysis identified deficiencies in the… Read more »