Transcription of INTERAGENCY FAIR LENDING EXAMINATION PROCEDURES
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INTERAGENCY FAIR LENDING EXAMINATION PROCEDURES
_____. Office of the Comptroller of the Currency Federal Deposit Insurance Corporation Federal Reserve Board Office of Thrift Supervision National Credit Union Administration _____. INTERAGENCY fair LENDING EXAMINATION PROCEDURES August 2009. CONTENTS. INTRODUCTION i PART I - EXAMINATION SCOPE GUIDELINES 1. Background 1 Step One Develop an Overview 5. Step Two - Identify Compliance Program Discrimination Risk Factors 6. Step Three - Review Residential Loan Products 7. Step Four - Identify Residential LENDING Discrimination Risk Factors 8. Step Five - Organize and Focus Residential Risk Analysis 12 Step Six - Identify Consumer LENDING Discrimination Risk Factors 12 Step Seven Identify Commercial LENDING Discrimination Risk Factors 13 Step Eight - Complete the Scoping Process 13 PART II - COMPLIANCE MANAGEMENT REVIEW 15.
not necessary to establish that a lender's adoption or implementation of a policy or practice that has a disparate impact is in violation of the FHAct or ECOA. These procedures do not call for examiners to plan examinations to identify or focus on potential disparate impact issues. The guidance in this Introduction is intended to help examiners
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