Fair Lending: Clearing the Fog

There are words, and then there are words. One of those words is proactive. While overused, the word has connotations that shouldn’t be dismissed—especially in the world of compliance. Last year, the FRB, in their 3rd Quarter Compliance Outlook (https://consumercomplianceoutlook.org/2020/third-issue/the-benefits-of-a-proactive-compliance-program) focused on the concept of proactive and discussed the FRAM automotive oil filter brand and [...]