1 + 1 = 2; Uh-oh, they did it again
Posted by Anthony Demangone
Sometimes, an issue can be as easy as a math equation.
The GAO issues a report critical of NCUA in the area of fair lending. (Here's an earlier post about the GAO report.)
+
NCUA issues NCUA Regulatory Alert 09-RA-09Â to highlight new interagency fair lending examination procedures.
=
A greater emphasis by NCUA on fair lending in general. You've been warned.Â
What is stressed in the new procedures? According to NCUA:
The FFIEC updated the procedures previously in effect since 2000 to expand upon the general guidance for identifying areas of potential risk. In addition, the procedures also address important contemporary issues such as:
- The risks and potential fair lending implications associated with using brokers or other third party entities for various aspects of lending operations;
- ManagementâÂÂs practices relative to loan pricing and procedures for detecting potential disparities; and
- ManagementâÂÂs practices for ensuring policies and procedures do not result in the inappropriate steering of borrowers to higher priced loan products.
***
I think HUD updated their FAQ document.  Again.  This is the third version of the FAQ.  And the new versions of the FAQ are issued with little fanfare. We'll have to keep a close eye on this.