Program Overview
Fair Lending School
addresses the two fair lending statutes (Equal Credit Opportunity Act and
Fair Housing Act) and how to conduct a fair lending examination using the
Interagency Fair Lending Examination Procedures.
The course consists of lessons, group exercises, and a case study that takes
the students through a fair lending examination step by step, including the
creation and presentation of a fair lending memorandum. Participants
actively take part in group case studies and other classroom activities.
The pre-course learning activities are critical to the
completion of the course and must be submitted prior to attendance.
Key
Objectives
Upon completion of this course, participants will be able to:
- Conduct a fair lending examination at a small institution.
- Understand theories of discrimination and the associated elements
required of each theory (overt, disparate treament, and disparate impact).
- Become familiar with the overall fair lending examination process.
- Write a Fair Lending memorandum.
- Understand and apply the risk scoping guidelines.
- Determine the focal point (product, market, decision center, and
target/controls groups, otherwise known as PMCG) based on the risk profile
analysis.
- Learn and practice effective techniques for conducting and documenting
fair lending interviews.
- Conduct a comparative file analysis using benchmarks and overlaps.
- Effectively conduct and document follow-up interviews with bank
management.
- Evaluate management's responses to apparent differences in treatment.
- Understand the fair lending findings that are to be included in the
Report of Examination.
- Explain the FDIC's consultation process.
Duration
This school is a one-week course.
Level
Basic
Target
Audience
This course is designed for
pre-commissioned compliance examiners who generally have 18
months of experience in compliance examinations.
Prerequisites
The pre-commissioned examiner must complete the
following before attending Fair Lending School:
- Review Regulation B
- Complete the Regulation B Computer-based Instruction
(CBI) tutorial
- Review 24 CRF 100.110 - 100.135
- Complete the fair
Housing Act CBI tutorial
- Review the Fair Lending Examination Procedures
- Review Outstanding Guidance on Low-Risk Fair Lending Examinations
- Review
the Interagency Policy Statement on Discrimination in Lending
- Review the
questions and answers on the FDIC Fair Lending Discussion Board
- Assist on
a Fair Lending Examination
Participants should also be familiar with Lesson Plan IV. Fair Lending
Examinations of the DSC Compliance On-the-Job Reference Guide.
Participants should have a working knowledge of Microsoft Excel.
Pre-Course Assignment
The Division of Supervision and Consumer Protection (DSC) has not authorized
official time as there are no pre-course requirements for the school.
Special Requirements
Participants are required to bring a laptop
and the most recent Examiner Reference CD to the session.
Post-Course Recommendation
Participants should be scheduled to conduct a fair lending examination as
soon as possible, but no later than three months after completing this
course to reinforce the skills learned from this session.
Post-Course Feedback
A Participant Assessment Form, which provides a comprehensive
analysis of the participant's in-class and project exercises, is sent to the
participant's field office approximately thirty days after the conclusion of
the school. The participant is assigned an overall rating of
"Satisfactory" or "Needs Improvement."
Credits
Continuing Education Unit (CEU): 3.4
Continuing
Professional Education Unit (CPE): 39
Federal
Deposit Insurance Corporation Corporate University is registered with the
National Association of State Boards of Accountancy (NASBA) as a sponsor of
continuing professional education on the National Registry of CPE Sponsors.
State boards of accountancy have final authority on the acceptance of
individual courses for CPE credit. Complaints
regarding registered sponsors may be addressed to the National Registry of
CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417. Web
site: www.nasba.org.
More
Information
For information regarding administrative policies such as complaints and
refunds, please contact Corporate University, Attn: NASBA Representative
Ava Livas, 703-562-2463, Room VS-A-3025,
3501 North Fairfax Drive, Arlington, VA 22226.
For more information concerning course content and administration,
please contact Dan Hotz at (703)
516-1266 or Kristine Fisk.
