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:
- 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
- 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
- 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.
This school is a one-week course.
This course is designed for
pre-commissioned compliance examiners who generally have 18
months of experience in compliance examinations.
The pre-commissioned examiner must complete the
following before attending Fair Lending School:
- Review Regulation B
- Complete the Regulation B Computer-based Instruction
- 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
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.
The Division of Depositor and Consumer Protection (DCP) has not authorized
official time as there are no pre-course requirements for the school.
Participants are required to bring a laptop
and the most recent Examiner Reference CD 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.
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."
Continuing Education Unit (CEU): 3.3
Professional Education Unit (CPE): 39.5
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
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.