by Ken Agle
What are the top three internet resources for analyzing Fair Lending? We could divide this question into a few categories, such as paid internet resources vs. free access resources. However, there is certainly some crossover, because the smart, solution-minded individual would directly pursue these avenues directly or ensure that the solution being used is committed to using these resources. Here are three core fair lending internet resources that every Fair Lending Officer should know about and that we as a firm exploit heavily.
Of course FFIEC.gov is our #1 source (and maybe our #2 and #3—it’s that good). It either serves as a destination site for massive analytics or provides a gateway to those sites. Pull it up and you’ll see that it serves a fairly broad number of potential interests. It includes Consumer Compliance elements, such as HMDA, CRA, the Geocoding and Mapping system and even the Census Reports. Click on any of those and you can literally spend days accessing key information that can prove helpful in analyzing your Financial Institution directly or conducting peer analysis. The Census Reports are a treasure-trove of insight that almost beg exploration. Other FFIEC resources include a wide array of key documents, such as those needed to understand the Fair Lending Examination guideline process. The resources within this site are nearly limitless and, when properly utilized, can aid in developing a powerful understanding of fair lending. in terms of both knowledge and application.
The Consumer Finance Protection Bureau runs consumerfinance.gov. Look around for a little while and you’ll see there is little question who is leading the charge on fair lending (and most of the rest of consumer compliance). This isn’t to say that other FFIEC members aren’t a force in the fair lending realm; but CFPB.gov is a must-know resource. From the “Submit a Complaint” and related tracking to the Law & Regulation section which lays out key updates on all core regulations (including Fair Lending laws), to the newsroom section, the CFPB site gives the info-explorer a front-row seat to consumer compliance, including the latest trends in Fair Lending.
Department of Justice
The DOJ’s site (http://www.justice.gov) seems ominous in its own right and clearly goes beyond fair lending. However, it remains one of the more useful websites for gaining material insight into situations where injustice in lending was observed, investigated and ultimately penalized.
There are many ways to explore the site, but one of the easiest is to go to the “Search the Site” and type in “Fair Lending.” You won’t be disappointed if you want reading material on the subject. At the time of this writing, the site provides access to 1,510 articles covering everything from case filings against financial institutions to summaries of coordinated Fair Lending efforts between the regulatory agencies and the DOJ. Hopefully, you never find your financial institution on this website. One of the key steps to avoiding it is to know what caused those presented institutions to become “DOJ-worthy.”
While other internet resources are available to the avid researcher, analyst, and so on, these are the first three you should know if you’re involved in Fair Lending at your institution. If you would like additional assistance, we invite you to contact us to help you navigate your FI to sound Fair Lending risk management.