Conducting a Fair Lending Self Assessment Britt Faircloth, CRCM April 2018 Florida Bankers Association Notice The information presented in this seminar summarizes general guidance and is intended only to act as a quick reference and not as a substitute for the law, regulations or official commentary. There are continuing, ongoing developments in this area. Therefore, always consult official sources of information, including the regulation text and official commentary, for a complete understanding of the law, including the regulations. Wolters Kluwer Financial Services, Inc. 2017 All rights reserved 2 1
Changes at the Top CFPB Go No Further Growing out of the 2007 2008 financial crisis, the CFPB had been a dominant regulator, with an unprecedented size and scope of enforcement. With their rule writing authority for numerous regulations, the impact of the Bureau has been felt even by smaller institutions who are not directly supervised by the Bureau itself. Since the departure of director Richard Cordray last fall, there has been a lot of activity: Contested Leadership: CFPB s acting director, and Office of Management and Budget (OMB) director Mick Mulvaney appears to have won legal battles for the position over Cordray s appointment, CFPB Deputy Director Leandra English. So far, Mulvaney has ordered a short freeze on new rulemaking, review of all CFPB activities, and has set forth the primary mantra for the CFPB: go no further. In general, this is a reversal of regulation by enforcement, and a focus on quantifiable and unavoidable harm to the consumer. 2018 Wolters Kluwer All rights reserved 4 2
So can you stop with all the analytics? 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 5 CFPB s Strategic Plan: 2018 2023 The CFPB Strategic Plan, issued in February, 2018, provides a new mission statement for the CFPB, and sets out four guiding principles for the CFPB moving forward: Seeking the counsel of others and making decisions after carefully considering the evidence Several RFIs (Requests for Information) to date: including revisions to the civil investigative demand (CID) process, administrative adjudications, and enforcement procedures Equally protecting the legal rights of all Confidently doing what is right Acting with humility and moderation Using these principles, the Bureau intends to pursue three strategic goals over the next five years. 2018 Wolters Kluwer All rights reserved 6 3
CFPB s Strategic Goals 1. Ensure that all consumers have access to markets for consumer financial products and services. A core element of this goal appears to be a focus on the cost benefit balance of regulations, as well as addressing unwarranted regulatory burdens 2. Implement and enforce the law consistently to ensure that markets for consumer financial products and services are fair, transparent, and competitive. Important objectives in meeting this goal include protecting consumers from unfair, deceptive, or abusive acts and practices (UDAAPs) and from discrimination; as well as leveling the playing field between depository institutions and other financial institutions to promote fair competition 3. Foster operational excellence through efficient and effective processes, governance, and security of resources and information. Here the CFPB will focus internally on enhancing safeguards for the Bureau's information and systems; maintaining a talented, diverse, inclusive, and engaged workforce; and managing risk and promoting accountability within the Bureau 2018 Wolters Kluwer All rights reserved 7 Enforcement via Other Avenues It would not be surprising to see enforcement actions from local governments or private litigation, including class actions: City Enforcement In May, 2017 the Supreme Court held that the City of Miami could file suit against Bank of America and Wells Fargo for predatory lending under the Fair Housing Act State Enforcement While we have seen less activity from states in the fair lending arena, states have been asserting their rights to protect their citizens. Wells Fargo, for example, was sued by the State of California both for privacy issues and the opening of unauthorized accounts 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 8 4
Assessing Risk (Scoping) Setting the Scope Loan products (what types of loans? Hot topics?) Geographic markets (where did you lend?) Decision centers (who made the decisions?) Timeframes (how far back will they look?) Prohibited basis groups (target groups) Control groups (used in comparisons) EACH POTENTIAL COMBINATION = 1 FOCAL POINT 10 5
Understanding Credit Operations Background Information Relevant background information: Types and terms of products offered Volume of, or growth in, each product Demographics of credit markets that you operate in Organization of decision making processes Centralized versus decentralized Types of documentation available Relative quantity, quality, and accessibility of data 11 Understanding Credit Operations Geographic Areas To which MSAs do you lend the most? Where is the risk? Examiners are instructed to narrow focus to: Geographic Areas or Underwriting Centers with the highest disparities in denial rates between control groups and minorities If a decision center has less than 5 racial or national origin denials Examiners should not examine for racial discrimination However, other indications might still indicate the need for review Example 19 males get lower rates than almost all 4 females 12 6
Potential for Discriminatory Conduct STEP 1: OVERVIEW Which products were reviewed last time? Which prohibited basis groups have a high percentage in different markets? Which products and prohibited basis groups were reviewed by the institution during self tests or self evaluations? Interview Key Underwriting Personnel, and/or Review Underwriting Guidelines, Policies, and Standards What factors are used in the underwriting process for different products? Credit scoring systems in place What is guidance for handling overrides and exceptions? Pricing policies, including guidance for exercising discretion Interview guidance is contained in OCC s Fair Lending Handbook 13 Potential for Discriminatory Conduct STEP 2: Compliance Program Discrimination Risk Factors C2. Government Monitoring Information (GMI) is incomplete (or a large percentage is missing?) Term GMI now called demographic information on application form. Exam procedures say prohibited basis monitoring info C3. Data and/or recordkeeping problems compromised reliability of previous examination reviews C6. The institution has not updated compliance guidance to reflect changes in law or in agency policy 14 7
Potential for Discriminatory Conduct Step 3: Review Residential Loan Products This product line must at least be considered in the scoping of every institution engaged in the residential lending market Especially if servicing is included in house Divide Home Mortgage Apps by Loan Type and Purpose Home Purchase Home Improvement Refinance expanded HMDA will distinguish between cash out refinance and other refinance products Further groupings may be necessary (FHA,VA) 15 Potential for Discriminatory Conduct Step 4: Identify Residential Risk Factors Overt discrimination risk factors Underwriting risk factors Pricing risk factors Steering risk factors Redlining risk factors Marketing risk factors 16 8
Overt Risk Factor Indicators O1 O2 O3 O4 O5 Including explicit prohibited basis identifiers in the institution s written or oral policies and procedures (underwriting criteria, pricing standards, etc.) Collecting information, conducting inquiries or imposing conditions contrary to the express requirements of Regulation B Including variables in a credit scoring system that constitute a basis or factor prohibited by Regulation B or, for residential loan scoring systems, the FHAct Statements made by the institution s officers, employees or agents which constitute an express or implicit indication that one or more such persons have engaged or do engage in discrimination on a prohibited basis in any aspect of a credit transaction Employee or institutional statements that evidence attitudes based on prohibited basis prejudices or stereotypes 17 Underwriting Risk Factor Indicators *U1 Substantial disparities among the approval/denial rates for applicants by prohibited basis characteristic (especially within income categories) *U2 Substantial disparities among the application processing times for applicants by monitored prohibited basis characteristic (especially within the denial reason groups *U3 Substantially higher proportion of withdrawn/incomplete applications from prohibited basis groups applicants than from other applicants U4 Vague or unduly subjective underwriting criteria U5 Lack of clear guidance on making exceptions to underwriting criteria, including credit scoring overrides U6 Lack of clear loan file documentation regarding reasons for any exceptions to standard underwriting criteria, including credit scoring overrides *U7 Relatively high percentages of either exceptions to underwriting criteria or overrides of credit score cutoffs 18 9
Exactly What Is a Substantial Disparity? There are generally two separate tests: A benchmark disparity, expressed as a ratio of prohibited basis denial percentage divided by the control group denial percentage Is it 2 to 1? 1.5 to 1? 1.25 to 1? Any disparity that is Statistically Significant Question: If you don t have apparent disparities, can you skip fair lending file reviews entirely? 19 The Problem with Benchmarks Scenario # 1 White Denial Rate 10% Black Denial Rate 23% 500 White Applicants 20 Black Applicants RATIO is 2.30 to 1 Is this statistically significant? No Scenario # 2 White Denial Rate 30% Black Denial Rate 32% 10,000 White Applicants 3,000 Black Applicants RATIO is 1.07 Is this statistically significant? Yes 20 10
Pricing Risk Factor Indicators P1 P2 P3 Financial incentives for loan officers or brokers to charge higher prices (including interest rate, fees and points). Special attention should be given to situations where financial incentives are accompanied by broad pricing discretion such as through the use of overages or yield spread premiums Presence of broad discretion in loan pricing (including interest rate, fee, and points), such as through overages, underages, or yield spread premiums. Such discretion may be present even when institutions provide rate sheets and fees schedules, if loan officers or brokers are permitted to deviate from those rates and fees without clear and objective criteria Use of risk based pricing that is not based on objective criteria or applied consistently *P4 Substantial disparities among prices being quoted or charged to applicants who differ as to their monitored prohibited basis characteristics P5 Consumer complaints alleging discrimination in residential loan pricing *P6 In mortgage pricing, disparities in the incidence or rate spreads of higher priced lending by prohibited basis characteristics as reported in the HMDA data *P7 A loan program that contains only borrowers from a prohibited basis group, or has significant differences in the percentages of prohibited basis groups 21 Pricing Risk What is Substantial? Is a 10 basis point, or a 15 basis point, disparity in loan rates between protected class and non protected class acceptable? Cases have been brought against institutions for unexplained pricing differences of only 4 basis points Understand how and why disparities exist 22 11
Steering Risk Factor Indicators S1 Lack of clear, objective, and consistently implemented standards for referring applicants to subsidiaries, affiliates, or lending channels, classifying applicants as prime or sub prime borrowers, or deciding what types of alternative loan products should be offered or recommended S2 Financial incentives for loan officers or brokers to place applicants in nontraditional products or higher cost products *S3 For an institution that offers different products based on credit risk levels, any significant differences in percentages of prohibited basis groups in each of the alternative product categories *S4 Significant differences in the percentage of prohibited basis applicants in loan products or products with specific features relative to control group applicants *S5 For an institution that has one or more sub prime mortgage subsidiaries or affiliates, any significant differences by loan product, in the percentage of prohibited basis applicants of the institution compared to the percentage of prohibited basis applicants of the subsidiary(ies) or affiliate(s) *S6 For an institution that has one or more lending channels that originate the same loan product, any significant differences in the percentage of prohibited basis applicants in one of the lending channels compared to the percentage of prohibited basis applicants of the other lending channel S7 Consumer complaints alleging discrimination in residential loan pricing or product placement *S8 For an institution with sub prime mortgage subsidiaries, a concentration of those subsidiaries branches in minority areas relative to its other branches 23 Marketing Risk Factor Indicators M1 M2 M3 Advertising patterns or practices that a reasonable person would believe indicate prohibited basis customers are less desirable Advertising only in media serving non minority areas of the market Marketing through brokers or other agents that the institution knows (or has reason to know) would serve only one racial or ethnic group in the market) 2018 Wolters Kluwer All rights reserved 24 12
Redlining Risk Factor Indicators *R1 Significant differences in the number of applications received, withdrawn, approved not accepted, and closed for incompleteness or originated in areas of the institution s market with a high concentration of minority group residents compared with areas of low concentration of minority group residents *R2 Significant differences between approval/denial rates for all applicants in areas with a high concentration of minority group residents compared with areas with a low concentration of minority group residents *R3 Significant differences between denial rates based on insufficient collateral *R4 Significant differences in the number of originations of higher priced loans or loans with potentially negative consequences for borrowers R5 Other patterns of lending identified during the most recent CRA exam that differ by concentration of minority residents R6 Explicit demarcation of credit products 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 R7 Differences 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 25 Final Steps in Scoping Organize residential risk factors Identify consumer risk factors Because of the lack of prohibited basis information, examiners may use surrogates such as Hispanic or Asian surnames, first names (for gender), or another surrogate Otherwise known as proxies In September of 2014, CFPB released a detailed paper Using publicly available information to proxy for unidentified race and ethnicity AKA BISG (Bayesian Improved Surname Geocoding) Identify commercial lending risk factors 26 13
Commercial Lending Risk Factors Examiners should consider a risk factor review for commercial lending, if: Substantial amount of lending in the commercial lending market, particularly small business lending product has not recently been examined underwriting standards have changed since the last examination Such an analysis should generally be limited to determining risk potential based on risk factors U4 U8; P1 P3; R5 R7; and M1 M3. 27 Commercial Lending Risk Factors Marketing and Redlining M1 M2 M3 R5 R6 R7 Advertising patterns or practices that a reasonable person would believe indicate prohibited basis customers are less desirable Advertising only in media serving non minority areas of the market Marketing through brokers or other agents that the institution knows (or has reason to know) would serve only one racial or ethnic group in the market) Other patterns of lending identified during the most recent CRA examination that differ by the concentration of minority residents 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 concentration of minority residents Difference in services available or hours of operation at branch offices located in areas with concentration of minority residents when compared to branch offices located in areas with concentration of non minority residents 2018 Wolters Kluwer All rights reserved 28 14
Commercial Lending Risk Factors Underwriting U4 U5 U6 U7 U8 Vague or unduly subjective underwriting criteria Lack of clear guidance on making exceptions to underwriting criteria, including credit scoring overrides Lack of clear loan file documentation regarding reasons for any exceptions to standard underwriting criteria, including credit scoring overrides Relatively high percentages of either exceptions to underwriting criteria or overrides of credit score cutoffs Loan officer or broker compensation based on loan volume (especially loans approved per period of time) 2018 Wolters Kluwer All rights reserved 29 Commercial Lending Risk Factors Pricing P1 P2 P3 Financial incentives for loan officers or brokers to charge higher prices (including interest rate, fee, and points). Special attention should be given to situations where financial incentives are accompanied by broad pricing discretion (as in P2), such as through the use of overages or yield spread premiums Presence of broad discretion in loan pricing (including interest rate, fee, and points), such as through overages, underages, or yield spread premiums. Such discretion may be present even when institutions provide rate sheets and fees schedules, if loan officers or brokers are permitted to deviate from those rates and fees without clear and objective criteria Use of risk based pricing that is not based on objective criteria or applied consistently 2018 Wolters Kluwer All rights reserved 30 15
Assessing Performance Performance Assessment Process Flow File Review Broker/Dealer Analysis Comparative File Results Regression Analysis Other Risk Assessment Reports Focal Points on public data Results of the last exam/consumer complaints Data Integrity (HMDA data & Fair Lending data) 11 16
Data Integrity Remember that any self assessment is dependent on the accuracy of the underlying data HMDA fields are often subjected to a data validation process, but other fields and other lines of business such as credit card or auto lending may have data points that have not been validated Consider reviewing a sample of the data points for lines of business that have not been subject to a data validation process Credit quality and pricing fields are particularly critical At a minimum, check key fields for reasonableness and completeness For example, does a DTI of 203% make sense on an originated loan? What about a negative DTI or negative credit score? Are there fields that are not populated? 33 Last Exam Results/Consumer Complaints What action items were left over from the last exam? Are examiner suggestions really just that? Do you have a consumer complaint tracking process? Are you monitoring complaints for trends and risk indicators? Are you seeing complaints that allege discrimination or unfair treatment? Are any such complaints happening in the same region or branch or from the same originator? 34 17
Marketing and Redlining Management of Geographies REMA While CRA has generally focused on a defined assessment area, fair lending can often focus on a broader Reasonably Expected Market Area, or REMA. Consider using mapping to overlay the assessment area and REMA to: Provide a consolidated view of performance and risk Determine which areas to utilize in self assessments Set goals that can help with both fair lending and CRA performance Determine areas where marketing efforts could be most successful 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 36 18
Mapping Regulators and consumer advocacy groups are using maps as a tool in monitoring institutions under both Fair Lending and CRA which makes it increasingly critical that institutions utilize mapping 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 37 Managing Geographies Assessment Area vs REMA 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 38 19
Redlining Cases Assessment Area 39 Redlining Cases Assessment Area and Branch Locations 40 20
Lending Distribution Institutions should be monitoring the volume of applications and originations by area (either assessment area or REMA) When analyzing lending distribution, two questions arise: What comparative factors should be evaluated? Aggregate for the area Aggregate excluding non bank contributors Individual peers or peer groups Demographic Data How much is enough? Below 85% can generally be considered low Below 50% should be considered an area of priority 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 41 Assessing Lending Performance Marketing and Redlining 42 21
Redlining Cases Application Volume 43 Underwriting & Pricing 22
Comparative File Review ( Matched Pairs ) SECTION C, PART III: Perform Transactional Underwriting Analysis Document everything about each loan, including: Qualifications according to policy guidelines Levels of assistance Reasons for denial (As of 1 1 2018 required for ALL institutions) Loan terms Goal to identify cases where similarly qualified prohibited basis and control group applicants had different credit outcomes 45 Comparative File Review Factors to Consider HMDA Data Credit Data Other Information Loan Purpose Credit Score USED IN THE Rate Lock Date DECISION or PRICE Loan Type LTV/CLTV Rate Type Occupancy (Investment vs Second Home?) Lien Status Property Type DTI Bankruptcy (within a certain time period?) Loan Program Specifics Existing Customer? 46 23
Comparative File Review Analysis 47 Pricing Comparative File Review Analysis 48 24
Best Practices Fair Lending Best Practices Risk Assessments Develop a comprehensive Risk Assessment to establish a baseline for fair lending compliance Identity inherent risk, risk controls and residual risk Prioritize fair lending reviews based on risk characteristics Update the risk assessment annually 50 25
Fair Lending Best Practices Monitoring Include all lending products Include all parts of the process Advertising remember to include all channels Application process (including brokers and other third party originators) Processing Underwriting periodic underwriter interviews or questionnaires Underwriting EVERY decision should be clearly and adequately documented Pricing especially discretionary components Servicing Loss Mitigation, Collections, Foreclosure, etc. 51 Fair Lending Best Practices Policies & Procedures Maintain clear, concise, up to date policies and procedures Help personnel understand how to comply with fair lending regulations Help personnel understand what is expected of them when complying with fair lending regulations Review and update Policies and Procedures annually Make Policy and procedures available via the company Intranet Web site Keep Policies and Procedures updated for new products, new processes, new channels Make sure written procedures match your institution s actual practices! 52 26
Fair Lending Best Practices Marketing and Advertising Review marketing and advertising material presented to potential borrowers Advertising collateral Website content Radio or TV adds Sponsorships Social media Review information presented to employees Intranet New product and process information 53 Fair Lending Best Practices Training Create and deliver a robust training program Who can conduct training? What sources, training materials may be used? Who must attend and how often? Review and update the training program as needed. New Hire training Providing training to third parties (see requirement for ALLY Bank) and to lending personnel (see Bancorp South consent order) General and/or Specialized training Board of Directors 54 27
Self Assessment Plan Determine what to review: Conduct a Fair Lending Risk Assessment and determine which products present the highest Fair Lending risk Perform self assessments of the areas with the highest risk Determine frequency: Quarterly or more frequently for large institutions, less often if smaller At a minimum, monitor by prohibited basis groups for: Denial and approval ratios Pricing disparities APR, Rate Spread (reportable and raw) Ratio of loans over the HMDA reportable threshold Redlining and steering risk 55 Analytics in 2018 and Beyond 28
Expanded Data New Analytics Challenges The expansion of HMDA data will create new challenges in analytics across many areas, including: Public Data National Origin Underwriting Pricing Redlining 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 57 New Challenges Public Data Although there remains some uncertainty around which of the 110 HMDA data fields will be available to the public, there is the potential for an increase in negative publicity and complaints alleging discrimination with an expanded public data set: Currently only a minimal amount of the data will be redacted or modified The modified data set will create added burden to analytics by creating a different set of focal points for institutions to monitor It is possible that certain groups could have unrestricted access to the full data set the Bureau believes that HMDA s public disclosure purposes may be furthered by allowing academics and industry and community researchers to access the unmodified HMDA dataset through a restricted access program, for research purposes. 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 58 29
Program Enhancements Public Data Robust complaint monitoring is key: Identify trends and key risk indicators Include identification data points such as region, branch, and/or originator in order to identify areas of concern Be prepared to analyze data in both the modified public format along with the unmodified data set regulators will have access to. Modified fields such as Age and Debt to Income may create new focal points for community groups, and subsequently, institutions 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 59 New Challenges National Origin Expanded Demographic Information will now allow for applicants to select disaggregated categories for race and ethnicity. These disaggregated categories can give an indication of disparate impact or disparate treatment based on National Origin which was a prohibited basis that was almost impossible to get to with the old HMDA data set National Origin is a prohibited basis group under both the Equal Credit Opportunity Act (ECOA) and Fair Housing Act (FHA) 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 60 30
Program Enhancements National Origin In addition to monitoring for disparities based on Race, Ethnicity, Gender, and Age; National Origin will need to be factored into analytics including: Marketing and Redlining Underwriting Pricing 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 61 New Challenges Underwriting Some fields in the expanded data set have not generally been a part of analysis in the past. AUS result, for example, is likely to be utilized as a test for disparate treatment. 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 62 31
Program Enhancements Underwriting Monitoring AUS Result will become an integral part of underwriting analysis: AUS result and action mismatch Research instances in which the AUS result indicates approve but the action is declined Does documentation support a valid, non discriminatory reason for denial? AUS caution results These tend to be more marginal deals and can involve a greater amount of subjectivity Who gets a caution result and is subsequently approved? Who is subsequently denied? 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 63 New Challenges Pricing The new data set includes multiple new pricing fields such as interest rate, total loan costs, origination charges, lender credits, total points and fees, and discount points. There is potential for an increase in pricing enforcement actions based on the new fields are prohibited basis borrowers paying higher origination charges, for example? Remember all rate spreads will be reported as part of the expanded data set which could additionally drive an increased focus on pricing 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 64 32
Program Enhancements Pricing Robust pricing analysis will be a necessity to monitor for disparities in: Note Rate Rate Spread Fees Total Loan Cost Lender Credits Additional data points may be required based on pricing policies Region Product 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 65 New Challenges Redlining Increased pricing data points will allow for an increase in reverse redlining claims in instances where low and moderate income and/or majority minority areas show a disparity in: Origination fees Total loan cost Lender credits 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 66 33
Program Enhancements Redlining Pricing differences must be understood and explained. This may require additional data points. Do prices vary by: Product Region Use mapping where possible to have a visual representation Remember that public data can complicate this issue. The public data set will not include these additional fields utilized in the internal analysis and consumer groups may note disparities based on that lack of available detail 2018 Wolters Kluwer Financial Services, Inc. All rights reserved. 67 Questions 68 34
Resources from Wolters Kluwer Consulting Services Compliance Management System ( CMS ) Review Fair Lending Analysis Risk Assessments Compliance Program Diagnostic Services/Gap Analysis Data integrity Review CFPB and Bank Regulatory Exam Preparation and Remediation Regulatory training Business Process Outsourcing (BSP) for HMDA, CRA, and Fair Lending reporting and analytics Additional Information visit our website or call 800-261-3111 Technology Solutions CRA Wiz for data management, analysis and submission HMDA Wiz for data management, analysis and submission Fair Lending Wiz for analysis Browser Based Editing (BBE) for mortgage and community development data management CRA and Fair Lending Wiz Dashboards of compliance goal management OneSumX for Compliance Program Management Visit our HMDA Resource Center www.wolterskluwerfs.com/hmda 2018 Wolters Kluwer All rights reserved 69 November 4-7, 2018 Diplomat Hotel in Hollywood, Florida Registration is open! www.cracolloquium.com Wolters Kluwer Financial Services, Inc. 2017 All rights reserved 70 35
Resources http://www.consumerfinance.gov/guidance/supervision/manual/ http://files.consumerfinance.gov/f/201409_cfpb_report_proxymethodology.pdf http://files.consumerfinance.gov/f/201310_cfpb_hmda_resubmissionguidelines_fair lending.pdf http://www.wolterskluwerfs.com/insights/home.aspx http://www.justice.gov http://www.occ.gov/publications/publications by type/comptrollershandbook/fairlend.pdf http://www.ffiec.gov 71 Contact Information Britt Faircloth, CRCM Senior Regulatory Consultant, Advisory Services and Regulatory Relations, Compliance Solutions Wolters Kluwer Britt.Faircloth@wolterskluwer.com Barbara Boccia, CRCM, MBA, JD Senior Director, Advisory Services and Regulatory Relations, Compliance Solutions Wolters Kluwer Barbara.Boccia@wolterskluwer.com 2018 Wolters Kluwer All rights reserved 72 36
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