New Jersey Bankers Association 2017 Compliance University Fair Lending Redlining Risks

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1 New Jersey Bankers Association 2017 Compliance University Fair Lending Redlining Risks June 14, 2017 Presented by Rose N. Egbuiwe, Fair Lending Examination Specialist 1

2 Objectives Provide Insight on Fair Lending Review Define Redlining Review Redlining Risk Factors Provide an Overview of Redlining Analysis 2

3 Risk Based Fair Lending Review Fair lending reviews conducted in accordance with the FFIEC Interagency Fair Lending Examination Procedures. Fair Lending review focused on areas where institution exhibits highest level of fair lending risks. 3

4 Fair Lending Scope and Conclusions Memorandum Fair lending reviews are documented using the Fair Lending Scope and Conclusions memorandum (FLSC) FLSC contains series of questions and examiner summary sections Questions provided not intended to cover every potential risk The FLSC is published in the FDIC Compliance Examination Manual 4

5 Definitions Redlining Redlining: Illegal disparate treatment in which a lender limits access to credit, or provides less favorable terms of credit, because of the prohibited basis characteristic(s) of an area Reverse Redlining: Targeting a borrower or an area with less advantageous products or services based on prohibited characteristics 5

6 Definitions Majority Minority Majority Minority Census Tract (MMT) Minority population at least 50 percent Majority Asian Census Tract (MAT) Asian population at least 50 percent Majority Black Census Tract (MBT) Black population at least 50 percent Majority Hispanic Census Tract (MHT) Hispanic population at least 50 percent 6

7 Redlining Risk Factors R1. *Significant differences, as revealed in HMDA data, in the number of applications received, withdrawn, approved not accepted, and closed for incompleteness or loans originated in those areas in the institution's market that have relatively high concentrations of minority group residents compared with areas with relatively low concentrations of minority residents. R2. *Significant differences between approval/denial rates for all applicants (minority and non minority) in areas with relatively high concentrations of minority group residents compared with areas with relatively low concentrations of minority residents. R3. *Significant differences between denial rates based on insufficient collateral for applicants from areas with relatively high concentrations of minority residents and those areas with relatively low concentrations of minority residents. 7

8 Redlining Risk Factors (Continued) R4. *Significant differences in the number of originations of higher priced loans or loans with potentially negative consequences for borrowers, (i.e., non traditional mortgages, prepayment penalties, lack of escrow requirements) in areas with relatively high concentrations of minority residents compared with areas with relatively low concentrations of minority residents. R5. Other patterns of lending identified during the most recent CRA examination that differ by the concentration of minority residents. R6. Explicit demarcation of credit product markets that excludes MSAs, political subdivisions, census tracts, or other geographic areas within the institution's lending market or CRA assessment areas and having relatively high concentrations of minority residents. 8

9 Redlining Risk Factors (Continued) R7. Difference in services available or hours of operation at branch offices located in areas with concentrations of minority residents when compared to branch offices located in areas with concentrations of non minority residents. R8. Policies on receipt and processing of applications, pricing, conditions, or appraisals and valuation or on any other aspect of providing residential credit that vary between areas with relatively high concentrations of minority residents and those areas with relatively low concentrations of minority residents. R9. The institution s CRA assessment area appears to have been drawn to exclude areas with relatively high concentrations of minority residents. 9

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11 Redlining Risk Factors (Continued) R10. Employee statements that reflect an aversion to doing business in areas with relatively high concentrations of minority residents. R11. Complaints or other allegations by consumers or community representatives that the institution excludes or restricts access to credit for areas with relatively high concentrations of minority residents. R12. An institution that has most of its branches in predominantly non minority neighborhoods at the same time that the institution's sub prime mortgage subsidiary has branches which are located primarily in predominantly minority neighborhoods. 11

12 Steps In Conducting A Redlining Analysis 1) Identify and delineate any areas with majority high minority concentrations within the bank s CRA AA and reasonably expected market area (REMA). 2) Determine whether any minority area identified in Step 1 appears to be excluded, under served, selectively excluded from marketing efforts, or otherwise lessfavorably treated in any way by the institution. 3) Identify and delineate any non minority areas within the institution s REMA that the institution appears to treat more favorably. 12

13 Steps In Conducting A Redlining Analysis (Continued) 4) Identify the location of any minority areas located just outside the institution s CRA assessment area and market area such that the institution may be purposefully avoiding such areas 5) Obtain the institution s explanation for the apparent difference in treatment between the areas and evaluate whether it is credible and reasonable. 6) Obtain and evaluate specific types of other information that may support or contradict a finding of redlining. 13

14 Steps In Conducting A Redlining Analysis (Continued) AA versus REMA Assessment Area: The geographies used to assess performance under the Community Reinvestment Act Reasonably Expected Market Area: FFIEC Fair Lending Procedures defines as Where the institution actually marketed and provided credit, and where it could reasonably be expected to have marketed and provided credit REMA may be beyond or otherwise different from a bank s CRA assessment area 14

15 Why is the REMA important? The REMA is used to evaluate redlining risk The analysis will determine whether a bank is providing equal access to credit in its REMA. This will involve looking at whether the bank is: Not extending credit in certain areas Targeting certain areas with less advantageous products Offering different loans to different areas Not marketing residential loans in certain areas 15

16 Determining the REMA Discussion with bank management involved in lending Branching Marketing Efforts Print Advertising Calling Program Direct Mailings Brokers or Realtors Location/Areas Served Map and plot the bank s applications and originations 16

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20 Steps In Conducting A Redlining Review (Continued) Examiners also consider: Branches Loan Production Offices Loan Applications and Originations Marketing Complaints Other Information (such as credit demand and competition) 20

21 Redlining Analysis Takeaways Conduct your own redlining risk assessment on a REMA Review your bank policies and procedures for redlining risks Conduct comprehensive data analysis, including geocoding bank s loans and deposit activities Review all marketing Conduct branch and LPO analysis Compare your data to peer group and census data Document findings and business reasons 21

22 Resources Are You at Risk for Redlining? Understanding Your Reasonably Expected Market Area (REMA) and CRA Assessment Area newyork.html Outlook Live Webinar 2016 Interagency Fair Lending Hot Topics FFIEC Interagency Fair Lending Examination Procedures & Appendix Policy Statement on Discrimination in Lending html FDIC Compliance Examination Manual Fair Lending Laws and Regulations IV.pdf Fair Lending Scope and Conclusions Memorandum pdf Technical Assistance Program Managing Fair Lending Risk 22

23 FDIC Fair Lending Contacts Fair Lending Examination Specialist Rose Egbuiwe at Examination Specialist Dominick Sciame at 23

24 Fair Lending Redlining Risks Questions? Thank you! Now your case study 24

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