Fair Lending School 2.0

Module 13: Fair Lending Interview

Welcome to the Fair Lending Interview. As former examiners who wrote this course, this is one of our favorite modules. Everything that you have learned about your organization’s application process, underwriting and pricing procedures, denial process, steering and redlining risks - it all comes together in the fair lending interview. You are going to choose one or multiple lenders at your organization to do a fair lending interview with. You must first become the expert on how lenders do their job, and then you are going to ask them their process. The answers you get from them should match what you learned in your reviews, from policy, and within procedures. This is a crucial step, and it’s one that regulators use often.

There are several interview questions in the back of this module. Use those that are applicable to your organization as a starting point for your interviews. Don’t limit your interviews to just those questions. You can tailor it to fit your unique needs. You may also want to consider interviewing your marketing team if you have one. In addition, if your organization has a separate underwriting team, you will want to focus an interview on those individuals specific to underwriting. It’s common that when we conduct a fair lending audit that we talk to 5 or more individuals, depending on the size and complexity of the organization. You cannot get too much information in this step, so don’t be scared to reach out to different people to find your answers.

 

Module 14: Comparative File Analysis