News
How to Evaluate Fair Lending and CRA Software: What to Test Before You Sign
Every fair lending and CRA software evaluation starts the same way: a shortlist of vendors, a run of demos that all look competent, and a decision that has to be defended internally on something firmer than which interface felt nicer. The difficulty is that the differences between these products are mostly invisible in a demo. They show up eighteen months later, in an examination, when someone asks how a number was produced and the honest answer turns out to be that nobody knows. This is a guide to testing for that in advance. It is written from our side of the table — we sell one of these products — so treat the last section as the interested party it is. The first five are the questions we would ask any vendor in this category, including ourselves. What does fair lending…
HMDA Plus: What It Actually Changed in the LAR Workflow
The short version. If you have been told HMDA Plus is coming, the date is wrong by about a decade. It is the industry nickname for the expansion the CFPB proposed in 2014 and finalised on 15 October 2015, and most of it took effect on 1 January 2018. It is not a proposal you need to prepare for. It is the reason your LAR looks the way it does now. That matters more than a correction, because a good deal of the material still circulating about it is written in the future tense. If your process was built after 2018 you inherited the outcome without seeing the transition; if it was built before, some of the workarounds from that first filing season are probably still in it. Either way the useful question is not what HMDA Plus proposed. It is what it did to the workflow, and which of those…
What a Fair Lending Exam Actually Asks For
A fair lending examination is more predictable than it feels, because the procedure examiners follow is published. The Interagency Fair Lending Examination Procedures set out how scope is decided, what documents get requested, how a focal point is chosen, how files are compared, and what an institution's explanation has to establish to resolve a finding. If you know that sequence, you can assemble most of what will be asked for before it is asked for. This article walks the sequence in order. It is the counterpart to our guide to running a self-assessment, which covers testing yourself. This one covers what happens when someone else does the testing. The document, and which agencies use it The procedures were issued in August 2009 by the OCC, the FDIC, the Federal Reserve Board, the…
Fair Servicing: What Examiners Test in Servicing Data, and How to Test It First
Fair lending examination does not stop at the credit decision. A servicer that grants a forbearance to one borrower and denies it to a similarly situated borrower on a prohibited basis has a fair lending problem, even though no application was declined and nothing about it will ever appear on a HMDA loan application register. The CFPB instructs its examiners to test for precisely this. The data they need to do it does not live in your LAR. This article covers what those servicing decisions are, why origination-side testing cannot see them, and how the statistical methodology used on application data transfers to servicing data. It is also specific about where that methodology stops transferring cleanly, because that is the part most treatments of this topic skip. What fair servicing…
What Actually Counts as a Small Business Loan Under Section 1071
A financial institution is a covered institution under Section 1071 if it originated at least 1,000 covered credit transactions to small businesses in each of the last two calendar years, where a small business is one with gross annual revenue of $1 million or less. Both numbers changed on May 1, 2026, when the CFPB published a reconsideration final rule that raised the origination threshold from 100 and lowered the revenue ceiling from $5 million. If your institution is testing scope against the older figures, the test is wrong, not just outdated. The rule's definition of a small business, and where the revenue threshold sits Section 1071 of the Dodd-Frank Act only counts credit extended to a "small business," and the definition is entirely about gross annual revenue: $1 million or…
- How to Evaluate Fair Lending and CRA Software: What to Test Before You Sign
- How to Evaluate Fair Lending and CRA Software: What to Test Before You Sign
- HMDA Plus: What It Actually Changed in the LAR Workflow
- What a Fair Lending Exam Actually Asks For
- Fair Servicing: What Examiners Test in Servicing Data, and How to Test It First
- HMDA Plus: What It Actually Changed in the LAR Workflow
- How to Fix the 10 Most Common HMDA Edit Check Errors
- 2025 HMDA Filing: Your Complete Preparation Checklist for March 2
- How to Evaluate Fair Lending and CRA Software: What to Test Before You Sign
- What a Fair Lending Exam Actually Asks For
- Fair Servicing: What Examiners Test in Servicing Data, and How to Test It First
- What Actually Counts as a Small Business Loan Under Section 1071
- Section 1071 in 2026: What Lenders Need to Know About Small Business Lending Data
- How to Evaluate Fair Lending and CRA Software: What to Test Before You Sign
- Special Report: Geocoding - Achieving the Highest Accuracy
