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Compliance Training Program

Fair Lending School

Program Overview
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.

Key Objectives
Upon completion of this course, participants will be able to:

  • Conduct a fair lending examination at a small institution.
  • Understand theories of discrimination and the associated elements required of each theory (overt, disparate treament, and disparate impact).
  • Become familiar with the overall fair lending examination process.
  • Write a Fair Lending memorandum.
  • Understand and 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.
  • Learn and practice effective techniques for conducting and documenting fair lending interviews.
  • Conduct a comparative file analysis using benchmarks and overlaps.
  • Effectively conduct and document follow-up interviews with bank management.
  • Evaluate management's responses to apparent differences in treatment.
  • Understand the fair lending findings that are to be included in the Report of Examination.
  • Explain the FDIC's consultation process.

Duration
This school is a one-week course.

Level
Basic

Target Audience
This course is designed for pre-commissioned compliance examiners who generally have 18 months of experience in compliance examinations.

Prerequisites
The pre-commissioned examiner must complete the following before attending Fair Lending School:

  • Review Regulation B
  • Complete the Regulation B Computer-based Instruction (CBI) tutorial
  • Review 24 CRF 100.110 - 100.135
  • Complete the fair Housing Act CBI tutorial
  • Review the Fair Lending Examination Procedures
  • Review Outstanding Guidance on Low-Risk Fair Lending Examinations
  • Review the Interagency Policy Statement on Discrimination in Lending
  • Review the questions and answers on the FDIC Fair Lending Discussion Board
  • Assist on a Fair Lending Examination

Participants should also be familiar with Lesson Plan IV. Fair Lending Examinations of the DSC Compliance On-the-Job Reference Guide.

Participants should have a working knowledge of Microsoft Excel.

Pre-Course Assignment
The Division of Depositor and Consumer Protection (DCP) has not authorized official time as there are no pre-course requirements for the school. 

Special Requirements
Participants are required to bring a laptop and the most recent Examiner Reference CD to the session.

Post-Course Recommendation
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.

Post-Course Feedback
A Participant Assessment 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."

Credits
Continuing Education Unit (CEU): 3.3
Continuing Professional Education Unit (CPE): 39.5


Federal Deposit Insurance Corporation Corporate University 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 final authority on the acceptance of individual courses for CPE credit.  Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417.  Web site: www.nasba.org.

More Information
For information regarding administrative policies such as complaints and refunds, please contact Corporate University, Attn: NASBA Representative
Ava Livas, 703-562-2463, Room VS-A-3025, 3501 North Fairfax Drive, Arlington, VA 22226.

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.

For more information concerning course content and administration, please contact Steven Miller at (703) 516-1281 or Dawn Scaff at (703) 516-5797.

 


Last Updated 03/26/2014 supervision@fdic.gov