Fair Lending/CRA

home appraisal with two men inspecting windows

Is there any new fair lending risk that a financial institution should make sure is included in the Fair Lending Risk Assessment?

Answer: Yes. A new CFPB initiative has been developed known as PAVE – Property Appraisal and Valuation Equity. It is an Interagency Task Force to address inequity in home appraisals. Examiners will be looking to see how financial institutions ensure there is no appraisal bias in minority neighborhoods or minority homes by monitoring the financial …

Is there any new fair lending risk that a financial institution should make sure is included in the Fair Lending Risk Assessment? Read More »

fair with wooden blocks

Are there fair lending concerns when a financial Institution utilizes a third-party vendor that provides data for marketing or assists in the development of a credit underwriting model containing digital algorithms?

Answer: Yes. The Financial Institution needs to be aware of what makes up the data that is obtained and how the data is applied. These algorithms may be filtered by zip codes, level of education or purchasing behaviors. The Financial Institution needs to ensure the algorithms used do not cause disparate impact by eliminating protected …

Are there fair lending concerns when a financial Institution utilizes a third-party vendor that provides data for marketing or assists in the development of a credit underwriting model containing digital algorithms? Read More »

changes ahead signs

CRA Asset-size Thresholds Announced for 2021

The annual CRA asset-size thresholds for covered financial institutions were announced December 17, 2020 applicable for 2021. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. As a result of the 1.29% increase in the CPI, the levels …

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mortgage symbol

Loan Servicing & Loss Mitigation Are Fair Lending Risks Too!

As we are all in this unusual time of a pandemic with various levels of lockdowns and social restrictions and the resulting economic downturn, unemployment and business closures, many financial institutions are trying to wade through processes on how to help their customer base through modifications, deferments, waiving of fees and loan proceeds for small …

Loan Servicing & Loss Mitigation Are Fair Lending Risks Too! Read More »

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