Managing Fair Lending starts with knowing where you stand. AffirmX Risk Intel Center’s patented approach to combining the efficiencies of technology with the expertise of our people allows us to complete a Fair Lending Risk Assessment off site, saving you time and money. We start with an online questionnaire and artifact requests that you can upload via our secure platform. We finish with a written report that will give you a solid handle not only on where you stand, but with specifics of what to do next.
6 Core Areas Covered by an AffirmX Fair Lending Risk Assessment
- Environment, including supervisory matters. AffirmX will review the financial institution’s position relative to external factors, including its regulator, membership/customer base, etc. We will review data provided by the financial institution, such as prior examination reports, as well as external sources.
- Retail presence and marketing strategy. AffirmX will analyze the financial institution’s physical and marketing strategies. We will conduct a series of analyses on deposit and lending strategies, growth patterns, etc., and will review how the financial institution approaches its market/membership segment, etc.
- Credit administration. AffirmX will review the financial institution’s policies and approach to lending with material emphasis on credit decisioning, pricing, and applicant notifications.
- Exception management. AffirmX will evaluate the financial institution’s use of exceptions in decisioning, pricing and the setting of loan terms. We will analyze the tracking of exceptions, the review of exceptions and the impact on fair lending for both direct and indirect lending channels.
- Role of third-parties in the lending process. To the extent applicable, AffirmX will work to identify all third-parties involved directly or indirectly in the lending cycle from marketing to servicing and collections. We will perform an analysis of the risk associated with those third-parties through direct activities on behalf of the financial institution or through the third-party’s own activities that may impact the financial institution’s fair lending performance.
- Technical compliance. AffirmX will review the technical requirements associated with Fair Lending including a sampling of the financial institution’s HMDA submission accuracy, Fair Lending-related disclosures and an expanded analysis of the handling of non-funded applications.
For more information regarding an AffirmX Fair Lending Risk Assessment, please contact us.