Fair Lending
California's New Fair Lending Exam Law: What State-Chartered Banks, Credit Unions and Mortgage Licensees Should Have Ready
California's Fair Lending Examination Act (AB 801, Chapter 871 of 2026) requires the Department of Financial Protection and Innovation to examine state-chartered banks and credit unions that meet HMDA's loan-volume test, and every residential mortgage lender and servicer licensee, for compliance with federal and California anti-discrimination law in mortgage lending. Banks and credit unions get an exam at least once every four years. Licensees get it inside their existing exam, which must happen at least every 48 months. Governor Newsom approved the bill on September 30, 2026. It is a non-urgency statute with no operative date of its own, so under Article IV, Section 8(c)(1) of the California Constitution it takes effect on January 1, 2027. Everything below is read from the chaptered…
Fair Lending Regression Analysis: What It Controls For and How to Explain a Pricing Disparity
A fair lending regression tests whether a gap in a lending outcome, such as denial or the rate paid, between a prohibited basis group and a control group survives once the credit factors your policy actually uses are held constant. What survives is the part you will be asked to explain, and the model shows which applications drive it. This article covers the working side of that: what goes into the model, how to read what comes out, and how examiners use the result. It is the companion to what regression can and cannot prove in fair lending, which deals with the method's limits in detail, quoting the OCC's handbook. If you have not read that one, the short version is that a model can only account for the factors you give it. What is a fair lending regression actually testing? Two…
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 six are the questions we would ask any vendor in this category, including ourselves. What does fair lending…
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…
- How to Benchmark Your CRA and HMDA Lending Against Peer Data
- HMDA vs CRA vs Section 1071: What Each Rule Collects and Who Has to File
- 2026 HMDA Data: Your Filing Checklist for the March 1, 2027 Deadline
- HMDA Plus: What It Actually Changed in the LAR Workflow
- What Actually Counts as a Small Business Loan Under Section 1071
- How to Fix the 10 Most Common HMDA Edit Check Errors
- CFPB and DOJ Settle Redlining Claims Against Non-Depository Mortgage Companies Before Change in Administration
- CFPB, DOJ Order Trident Mortgage Company to Pay More Than $22 Million for Deliberate Discrimination Against Minority Families
- Fair Lending Self-Assessment: A Step-by-Step Guide for 2026
- CFPB takes action against Nationstar Mortgage for flawed mortgage loan reporting
- CFPB Takes Action Against Fifth Third Bank for Auto-Lending Discrimination and Illegal Credit Card Practices
