Key Takeaways
- Fair lending violations carry the largest penalties and most personal liability of any lending compliance area.
- Discrimination can be proven through disparate treatment, disparate impact, or steering theories.
- Pricing discretion is the highest-risk area—loan officer discretion produces measurable disparities between demographic groups.
- Annual fair lending self-assessments using third-party consultants ($5,000-$15,000) demonstrate proactive compliance commitment.
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Test Your Knowledge
1.What does ECOA prohibit in the lending process?
2.What is disparate impact in fair lending?
3.What must a lender provide to a rejected applicant under ECOA?