As fair lending related enforcement actions grow more common, lenders find themselves searching for greater analytic and legal expertise. Expertise that Corporate Risk Advisors, with its unique blend of resources, can provide.

In our experience, it is far less costly for a company to have its lending analysis in place before a regulator begins the investigative process than it is to assemble the necessary information after the fact. While most companies monitor their fair lending performance in some way, there is a distinct difference between internal monitoring and assembling and preparing data that can readily be supplied to an investigating agency.

One of the services we offer our clients is an objective, third party review of their existing fair lending monitoring and reporting efforts. By comparing a company’s current approach to industry “best practices,” we can identify gaps that could lead to legal or regulatory exposure, and offer effective and workable solutions specifically geared to our client’s needs.

In addition, we routinely work with clients to assemble, analyze and explain their fair lending data, including data required to be reported to the Federal Reserve Board each year pursuant to the requirements of the Home Mortgage Disclosure Act (HMDA). Our analysis is designed to mimic how regulators and other interested parties will review the institution’s annual HMDA data, and is intended to provide a head-start on addressing any issues that might arise.

When appropriate, we perform comprehensive fair lending assessments of an institution’s lending practices using detailed underwriting data (e.g., credit scores, loan-to-value ratios, etc.). These assessments are designed to determine the extent to which adverse patterns revealed by the HMDA data can be attributable to differences in credit risk, and to identify the specific source(s) of any differentials that may remain.

Corporate Risk Advisors can also work with clients who prefer to have more immediate feedback on their HMDA performance than an annual or intermittent review can provide. Depending on the client’s needs, Corporate Risk Advisors can provide confidential, protected reports on a monthly or quarterly basis.

Our Fair Lending services are designed to meet the full range of client needs. Our services include:

• Best Practice Assessments
• Fair Lending Statistical Analyses
• Fair Lending Compliance
• Bank Agency Examination Compliance
• Matched-Pair Analysis
• Mystery Shopper Surveys
• Fair Lending Investigations
• Formal and Informal Investigations
• Document Assembly and Response
• Statistical Defense Preparation
• Expert Witness Services

For further information about our HMDA and Fair Lending services, please contact us.

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