Fair Lending Audit
Process and Methodology
NETBankAudit conducts a Fair Lending Audit to confirm compliance with Regulation B (Equal Credit Opportunity Act), Regulation C (Home Mortgage Disclosure Act - HMDA), the Fair Housing Act (FHA), and Unfair or Deceptive Acts or Practices (Regulation AA). The methodology is based on actual Fair Lending laws and regulations, the Consumer Compliance Handbook, and FFIEC and CFPB guidance. The institution’s specific risk factors determine the audit framework. The audit is considered a “self-test,” not a “self-evaluation,” so results do not have to be shared with regulators.
Scope of the Audit
- Comprehensive review of lending policies, procedures, and practices
- Loan officer and support staff interviews and training review
- Loan office inspections
- Consumer complaint review
- Disclosure and advertising review
- Loan file reviews for technical compliance, including HMDA reporting accuracy and Regulation B/FHA compliance
- Loan file reviews for fair lending practices, including statistical and judgmental sampling, prohibited basis analyses, and comparisons
The audit also determines that the institution accurately reports and submits mortgage loan information on the Loan Application Register (LAR), provides required forms and disclosures, ensures advertising is free of discriminatory implications, and reviews accepted and denied loan files for absence of discriminatory practices. A detailed report with objectives, scope, findings, and conclusions is provided, along with all supporting documentation and workpapers.