Compliance Training Program
Introduction to Fair Lending School
Introduction to 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.
Upon completion of this course, participants will be able to:
- Risk scope the underwriting, steering, pricing, redlining, and marketing portions of a fair lending review
- 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
- Conduct a comparative file analysis using benchmarks and overlaps
- Evaluate management's responses to apparent differences in treatment
- Conduct a fair lending examination for a small institution
- Write a Fair Lending Scoping and Conclusions Memo
This school is a one-week course.
Pre-course work (Independent Self Study), facilitated classroom discussion/lectures, small group activities, and in-class project.
This course is designed for pre-commissioned compliance examiners who generally have 6-10 months of experience in compliance examinations.
This course is open to appropriate staff of the FDIC and partner government regulatory agencies. This course is not open to the public or staff of private banks.
The pre-commissioned examiner must complete the following before attending Fair Lending School:
- Reviewed Regulation B and Staff Commentary
- Reviewed 24CFR Part 100 Subpart C (100.110 -100.135) HUD’s Implementing Regulation
- Reviewed Part 338 of the FDIC Rules and Regulations – Fair Housing
- Reviewed the Interagency Fair Lending Examination Procedures
- Reviewed the Interagency Policy Statement on Discrimination in Lending
- Participated in a Fair Lending Examination, including assisting in conducting interviews and preparing schedules and memo.
Participants should also be familiar with the “Equal Credit Opportunity Act (ECOA) and Fair Housing Act (FHA)” lesson plan of the DCP Compliance On-the-Job Training (OJT) Manual.
Participants should have a working knowledge of Microsoft Excel.
Prior to attending the Fair Lending School, participants must complete two Regulation B Computer Based Instruction Tutorials, six Excel Skilsoft courses, and watch the video “Theories and Elements and Standards of Proof."
The Division of Depositor and Consumer Protection (DCP) has authorized 16 hours of official time to complete the pre-course assignment.
Participants are required to bring a laptop to the session.
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.
Summary Evaluation 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."
Continuing Education Unit (CEU): 3.3
Continuing Professional Education Unit (CPE): 39.5
For information regarding administrative policies such as complaints and refunds, please contact Corporate University, Attn: NASBA Representative Ava Livas, Room A-3025, 3501 North Fairfax Drive, Arlington, VA 22226 (703) 562-2463.
FDIC 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 the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.
The FDIC has been approved as an Authorized Provider by the International Association for Continuing Education and Training (IACET) (www.iacet.org), 1760 Old Meadow Road, Suite 500, McLean, VA 22102.