FAIR LENDING, CRA & HMDA RISK MANAGEMENT
Providing the knowledge to keep you on the right path.
Home Mortgage Disclosure Act (HMDA)
HMDA data validations, including best practices regarding policies and procedures, and the impacts to Fair Lending and CRA performance.
Our process Identifies and mitigates fair lending risks identified in the Interagency Fair Lending Examination Procedures (IFLEP).
COMMUNITY REINVESTMENT ACT
Analyzes Lending, Investment, and Service Test performance and establishes meaningful performance context that explains how your bank is serving the lending and community development needs of low- and moderate-income people and geographies.
Understand the (HMDA) Home Mortage Disclosure Act
Home Mortgage Disclosure Act (HMDA) data validations, including best practices regarding policies and procedures, and the impacts to fair lending and CRA performance
Customized training sessions for your target audience, including compliance and audit staff, loan officers, and the board of directors.
Fair Lending, CRA & HMDA Risk Management Services
Comparative File Reviews evaluate your bank’s fair lending risk within your underwriting and pricing policies and practices. File reviews are conducted utilizing a vast understanding of the Interagency Fair Lending Examination Procedures and interpretations of the federal regulatory agencies.
Regulators have an expectation that banks will conduct fair lending audits in order to assess their risks and to bolster a bank’s fair lending risk management program.
The Fair Lending Risk Assessment identifies all fair lending risk regarding underwriting, pricing, redlining, marketing, and steering policies and practices. It follows the same methodology examiners use to set the scope of fair lending examinations. Having an accurate understanding of the risks faced by your institution is an important step in mitigating these risks and strengthening the fair lending risk management program. After weaknesses have been identified in the fair lending risk management program, we will propose tailored, common sense approaches to mitigate future fair lending risks.
Illegal redlining, which relates to serving minority geographies differently than non-minority geographies, continues to be a fair lending hot button and an area of regulatory focus. Wallace Consulting Co., LLC is the premier provider in conducting a comprehensive evaluation of the redlining risk faced by your institution, with a superior understanding of the techniques used to test for redlining discrimination. We also provide ongoing monitoring of your lending patterns and assistance in documenting your bank’s efforts to fully serve minority geographies per the requirements of Regulation B – Equal Credit Opportunity and the Fair Housing Act.
Community Reinvestment Act (CRA) Self-evaluations are available to banks of all sizes and utilize the appropriate Interagency CRA Examination Procedures based on the asset size of your bank. These self-evaluations assess your bank’s performance under the applicable tests used to evaluate CRA performance, including the Lending, Community Development, Investments, and Services Tests. The evaluation will also establish meaningful performance context that explains how your institution is addressing obstacles to serving the lending and community development needs of low- and moderate-income borrowers and geographies. We also process and formally communicate appeals of CRA ratings to appropriate regulatory agencies.
Monitoring of your Home Mortgage Disclosure Act loan application register and loan trial balance data provides an in-depth evaluation of the fair lending risks faced by your bank. These risks can result in regulatory concerns associated with underwriting, pricing, redlining, marketing, and steering. A bank that has a full understanding of the risk present in its lending data is more successful at addressing regulatory inquiries, public comments and complaints.
Michael was the lead instructor for the Federal Reserve System's fair lending class and he taught over 400 examiners how to evaluate fair lending risks, use the Interagency Fair Lending Examination Procedures, and assess the adequacy of fair lending risk management. Use his extensive experience in training your loan officers, staff, and board of directors. Michael also taught a Federal Reserve System CRA class and regularly instructed local examiners, bankers and the public on the requirements of the CRA examination procedures and techniques used to evaluate the performance of banks.
Fair lending and CRA training are customizable to the risks inherent to your institution. These laws and regulations are too complex to employ an “off-the-shelf” approach to training. We will work with your bank to design a training program based on the risks inherent to your bank’s policies and practices and the demographics of the markets in which you operate.
Providing the training to keep you up to date
Michael P. Wallace is the president and founder of Wallace Consulting Co., LLC. After over 19 years of serving banks as a compliance examiner with the Federal Reserve Banks of St. Louis and Dallas and the Arkansas State Bank Department, Michael found that the changing landscape of fair lending examinations and enforcement have left many banks in the dark. Professional service, commitment, and vast industry knowledge will mitigate your risks and improve your fair lending and CRA risk management programs.
During his time with the Federal Reserve Bank of St. Louis, Michael served as the fair lending subject matter expert and managed the Reserve Bank’s fair lending oversight program. He was the liaison to the fair lending enforcement team at the Board of Governors of the Federal Reserve System, reviewed every fair lending risk assessment/scope document produced by the Reserve Bank over a four-year period, and served as the fair lending examiner-in-charge of an examination that resulted in a settlement with the U.S. Department of Justice. He also trained over 400 Federal Reserve System examiners on fair lending examination techniques, authored numerous materials to train those examiners, and advised banks on the most effective ways to establish a strong fair lending risk management program and mitigate their fair lending risks. As a Supervisory Examiner, Michael provided oversight on well over 100 compliance and CRA examinations. He also taught a CRA examination techniques course to examiners and regularly provided fair lending and CRA training to examiners, bankers, and the public.
Wallace Consulting Company consults banks on how to mitigate their fair lending and CRA risks. In doing so, we foster banking practices that benefit consumers by complying with the Equal Credit Opportunity, Fair Housing, and Community Reinvestment Acts. We are committed to banks, but equal to our commitment to ensuring these important and life-impacting laws and regulations are followed to the letter.