Discrimination, disparate treatment, and disparate impact: three things you never want to see in an examiner’s findings. Do you understand how inadvertent discrimination can manifest? Has it unknowingly happened? Comparative file review can yield some answers.
- Understand how inadvertent discrimination can occur (disparate treatment and disparate impact)
- Conduct a comparative file review that will pass muster with examiners
- Self-identify problematic lending policies and processes that could be construed as a fair lending or redlining issue
- Ensure your fair lending related policies are strong
- Be confident about your next fair lending exam
Although overt cases of lending discrimination are infrequent, disparate treatment or disparate impact can occur inadvertently. Examiners expect financial institutions to conduct comparative file reviews to identify potential fair lending issues – which you want to find well before an examiner does!
Awareness, monitoring, and periodic comparative file review can lessen the likelihood of adverse issues arising. This informative webinar will walk through the steps of a comparative file review and provide worksheets and a sample report format to make it easier.
Ann Brode-Harner, Brode Consulting Services, Inc.
Ann Brode-Harner began her career in 1973 and has continued her service as a consultant to regional and community financial institutions through a wide range of areas including strategic planning, lending, deposits, marketing, training, compliance, and management. Ann is a well-respected presenter and has spoken to audiences across the country for over 30 years. She has presented sessions for numerous state associations and has taught at the School of Banking Administration at the University of Wisconsin as well as many other state banking schools. Ann is the author of The Bank Deposit Documentation Manual for Front-Line Personnel published by Bankers Publishing Company, and is well represented in numerous industry publications.