Fair Lending/Nondiscrimination Analysis


FRC provides services to assist management in taking a proactive approach to fair lending.

FRC follows procedures utilized by the regulatory agencies when comparing the credit terms and conditions extended to marginally-approved applicants to the terms requested on applications received from members of protected groups. FRC focuses specific attention on the application of pricing considerations involved in an institution’s credit underwriting and origination process.

This type of engagement utilizes a comparative, side-by-side file analysis designed to identify discriminatory practices which are not readily detected during a ‘technical’ review. FRC consultants compare individual applications and credit files, and review loan policies and underwriting guidelines for practices which could result in disparate treatment or have a negative impact toward members of protected groups.

FRC also provides an objective evaluation of loan policies, procedures, and guidelines. Based on our findings, our consultants work with management in developing Action Plans designed to improve compliance with fair lending issues.


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Recent Insight

Regulatory Bulletin: August 2017

August 21st, 2017 by rfriedman