Tuscan Club University

Fair Lending Complaints

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Hi! It’s Tory Haggerty from Tuscan Club University’s Fair Lending School and welcome to another Fair Lending Short.

In this Fair Lender Short I want to talk about Fair Lending complaints.  Now obviously you’re going to research any complaints that come through your door, but Fair Lending Complaints even more so. 

I want to share a quick story with you. During my years as an FDIC Examiner, we once had a complaint come through our office where a female minority customer went into a bank and asked to apply for a car loan and the lender said, “I know how you people are with car loans”. 

Spoiler alert, the customer was upset, left the bank, filed a complaint with us, and when we got to that exam, we didn’t do a full fair lending review, we didn’t do an overall program review, we looked at that complaint, that lender, that prohibited basis group. 

The point of the story is that one complaint was the entire focus of that Fair Lending Exam and as an FDIC Compliance Examiner we did exams every three years. So what I want you to take away from this is, take fair lending complaints very seriously. 

That entire exam cycle focused on one fair lending related complaint, so if you ever get a fair lending related complaint, make sure that you research it very thoroughly and get to the bottom of everything.  And make sure that you know exactly what happened, and that you have appropriate corrective action because it can and may be the focus of your next fair lending exam and it’s obvious that you’ll want to know all of the facts before the Examiners find them out.

Thanks for reading!


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