Fair and Responsible Banking

Fair and Responsible Banking/Fair Lending has never been more critical for financial institutions. The expectations from the regulatory agencies have increased in recent years driven by the Dodd-Frank Act, creation of the Consumer Financial Protection Bureau (CFPB), expanding state enforcement activity, and ever-increasing enforcement action penalties, among others. Banks must have effective compliance programs that evaluate and mitigate risk, including sophisticated statistical analytics capabilities.

Treliant has experts in fair lending and responsible banking that help institutions develop, evaluate, and implement robust compliance programs to address fair and responsible banking risks. Rather than simply identifying gaps or making recommendations, Treliant’s experts will help banks put into practice the tools and processes necessary for an effective program.

Our clients rely on our regulatory knowledge and industry experience to meet current mandates and achieve compliance and business objectives. 

Treliant's Fair and Responsible Banking Advisory Services include:

Developing a Robust Fair and Responsible Banking Risk Assessment Process

  • Objective Ratings
  • Identifying and Evaluating Controls
  • A Proven Formalized Methodology
  • Fair Lending Risk Statements and Questionnaires
  • Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Risk Statements and Questionnaires
  • Risk Performance Outputs for Management and Regulatory Reporting
  • Flexible Platform for Manual or Automated Integration with Governance, Risk, and Compliance (GRC) and Enterprise Risk Management (ERM) systems

Governance for Fair and Responsible Banking

  • Board-Appointed Fair Lending or Fair and Responsible Banking Officer
  • Board/Executive-Level Fair Lending or Fair and Responsible Banking Committee or Working Groups
  • Committee Charter
  • Fair and Responsible Banking Staffing, Sufficiency, Roles and Responsibilities
  • Formalized Meetings
  • Effective, Auditable Minutes
  • Reporting Protocols and Corrective Action Oversight
  • Formalized Documentation (including Program Document, Policy, and Procedures)

Developing and Performing Robust Statistical Testing

  • Regular (Quarterly, Semi-Annual, or Annual) Statistical and Regression Analyses
  • Data Validation and Testing
  • Data Integrity (“Scrub”) and Data Collection Process Improvement
  • Penetration and Ratio Analyses
  • Regression (including Triggers for Detailed Review)
  • Fair Lending Statistical Model Validation
  • Redlining Reviews for All Loan Types (including Branch Placement and Service Offerings)
    • Consumer, Commercial, and Indirect Auto Loan Testing, including Proxy Assignment and Consideration of Underwriting and Pricing Factors
  • Matched-Pair Testing
  • Detailed File Review (when necessary)
  • Design, Follow-Up, and Verification of Action Plan Effectiveness

Monitoring Controls and Second Reviews of Denials

  • Methodology
  • Outcomes
  • Reporting
  • Validation

Special Assistance in Areas with High Fair and Responsible Banking Risk

  • Private Banking
  • Small-Business Lending
  • Servicing, including Collections, Loss Mitigation, Repossession, and Foreclosure
  • External Influences such as Brokers, the Press, and Community Activist Groups

Comprehensive Fair and Responsible Banking Training

  • Real-Life Examples and Scenarios
  • Job-Specific Content Tailored to Your Institution
  • Development of an Ongoing Training Program

Regulatory Reporting and Response Preparation

  • Exam Preparation
  • Exam Response
  • Home Mortgage Disclosure Act (HMDA) and Community Reinvestment Act (CRA) Data Integrity (“Data Scrubs”)
  • Data Collection Process Improvement

Providing Critical Advice and Solutions in Other Areas, including:

  • Develop and Implement Robust Processes for Marketing, Product, and Service Reviews
  • Fair Lending Review of Existing and New Branch Locations
  • Coordinate and Assist with Community Reinvestment Act (CRA) Activities and Planning
  • Analysis of Discretionary Processes (Exceptions and Overrides)
  • Crisp, Comprehensive Policy and Procedures for Fair and Responsible Banking on an Enterprise-Wide Basis
  • Capturing and Monitoring Fair Lending and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Complaints
  • Develop Fair and Responsible Banking Programs, including Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)
  • Coordination of the Interactions between the Fair Housing Act, Equal Credit Opportunity Act (ECOA), Community Reinvestment Act (CRA), Home Mortgage Disclosure Act (HMDA), and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)
  • Develop Performance Context to Clarify and Mitigate Fair Lending and/or Community Reinvestment Act (CRA) Findings
  • Outsourced or Co-sourced Fair Lending and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Audits and Control Testing

If your needs are not addressed by the advisory services listed above, view more of our Services or 

Ask Us a Question

Video Spotlight

Carl G. Pry, Managing Director, addresses important fair and responsible banking topics, including compliance management systems (CMS), redlining, and statistical analyses.


B. Scott Fisher
Chief Executive Officer
Carl G. Pry
Managing Director
Mark Westmoreland
Managing Director
Lynn W. Woosley
Senior Director
Deanna B. Neal
Senior Manager

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Regulatory Compliance

Treliant has the advisory expertise and technical capacity to assess your compliance and fair lending programs, advise on necessary changes, and assist with implementation.

Learn more about Treliant's Regulatory Compliance Advisory Services.

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