Exam/Audit

Mystery Shopping Techniques & Strategies

Rule Synopsis: ECOA and the Fair Housing Act prohibit discriminatory treatment based on race, ethnicity, sex, public assistance income, familial status, disability and other factors. Disparate treatment between your clients can result in these allegations from the CFPB or HUD. One of the techniques used by the regulatory bodies is mystery shopping your frontline staff. [...]

2017-12-27T12:24:54-05:00November 3rd, 2017|

CFPB – FFIEC Releases Updated Information Security Examination Manual – September 2016

Rule Synopsis: Background: The FFIEC governs a few different regulations, such as the Bank Secrecy Act and Anti-Money Laundering regulations as well as HMDA and CRA procedures. They work in conjunction with the CFPB. The CFPB has supervisory authority over the mortgage banking industry, and can use this Information Security Examination manual during a CFPB [...]

2018-10-28T15:17:22-05:00November 3rd, 2017|

CFPB – Is Your Target Marketing Breaking Fair Lending Laws?

Rule Synopsis: American Express was fined by the CFPB over this issue for discrimination based on age. Two banks were fined because one targeted the Asian population, and another bank discriminated against white males. In all of these instances, the lender had a broader market to offer access to credit, and chose to market to [...]

2017-12-27T12:28:44-05:00November 3rd, 2017|

CFPB – Redlining and Mystery Shoppers – Dated June 29, 2016

Rule Synopsis: Background: ECOA prohibits lenders from discriminating based on race, sex, ethnicity and many other prohibited factors. Recently, the CFPB issued a fine against a bank entity for Redlining. This probe started due to Mystery Shoppers from the CFPB receiving Disparate (or varying) treatment based on their scenario. This article is going to focus [...]

2017-12-27T12:34:57-05:00November 3rd, 2017|

CFPB Monitoring Fair Lending Pricing and Underwriting Exceptions

[Download Checklist – CFPB Fair Lending & Underwriting Exceptions Guidelines ] Rule Synopsis: We use the terms exception, concessions, and discretion interchangeably in the mortgage world. However, the examiners really see them as the same thing. The bottom line is this: If your pricing engine or rate sheet indicates a particular rate/price combination for a [...]

2018-12-16T12:46:15-05:00November 3rd, 2017|