Fair and Responsible Banking
Our solutions help you meet regulatory requirements, manage risk, and foster sustainable growth while maintaining ethical and responsible business practices
Our fair banking experts have worked in bank and non-bank financial institutions, mortgage companies, Government Sponsored Entities, or have been former regulators. We offer a broad range of fair and responsible financial service solutions, including support for customer protection/UDAAP and Community Reinvestment Act (CRA) compliance.
- Redlining & geographical analyses of assessment areas and reasonably expected market areas (REMAs) including use of statistical (regression) and BISG methodologies to help our clients understand their lending performance, patterns, and peer institution comparisons
- Conducting community needs assessments to improve fair lending and CRA performance
- Marketing analysis of campaigns, outreach activities, and marketing propensity identification practices
- File reviews for comparative analysis of similarly situated minority and non-minority borrowers with differing loan outcomes
- Appraisal, underwriting exception, steering and fallout disparity, and complaint reviews and disparity analysis including use of Bayesian Improved Surname Geocoding (BISG) proxy methodology
- Default management process reviews to determine potential risks in collections, foreclosure, customer service, and bankruptcy
- Performance reviews with statistical analysis for call metrics, forbearance exit dispositions, portfolio delinquency rates, post-CARES Act and pandemic hardship forbearances
- Forbearance exit disposition analyses aimed at identifying statistically significance disparities between similarly situated minority and non-minority borrower groups with alignment of Regulation X’s delinquency definition
- Limited English Proficiency (LEP) servicing assessments to identify disparities in the collection, categorization, and effectiveness for LEP or minority borrowers
- Fair Banking and CRA governance – policies and procedures, roles and responsibilities, reporting and oversight
- Fair Banking risk assessment design and execution
- Fair Banking model development, execution, performance review, tuning, and independent validation
- HMDA and CRA data integrity, reporting, and filing
- Fair Banking and UDAAP testing, monitoring, and independent audit
- Fair Banking and UDAAP independent audit
- Fair Banking and UDAAP training content development and program design
- CRA Strategic Plans
- Fair Lending, Servicing and CRA regulatory examination readiness, response and remediation support
- Use of financial analysis and forensic investigations to assist legal teams in fair lending litigation matters, including analyzing lending data and identifying potential disparities in lending practices
- Expert witness reports and testimony in court or alternative dispute resolution settings, such as arbitration or mediation, related to fair lending claims
- Assistance to legal teams in discovery, including the review and analysis of lending data, and provide support for depositions and witness interviews
- Analysis of lending data to identify patterns or disparities that may indicate potential fair lending violations
- Preparation of demonstrative exhibits and visual aids to help communicate complex financial information related to fair lending claims to juries or other decision-makers
- Expert support for regulatory investigations and enforcement actions related to fair lending matters, including responding to subpoenas and other requests for information
Ready to Talk?
We work with you to understand your needs, so we can tailor our approach to your engagement. Learn more when you connect with our team.
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