Conducting my first Reg B compliance review. As part of the review, to determine if we have any apparent discrimination on a prohibited basis in the application process, I compared rates, terms and fees for various products....alongside the prohibited basis information I had collected for each application to see if there were any issues there...I also did compare originated loans to not originated loans.....this was not intended to be a true fair lending analysis...it was just to review Reg B prohibited basis rules.

Any advice appreciated....

I did note some concerns with our pricing....we offer a no closing cost home equity loan. I saw differences with respect to refinancing a loan an applicant already has with us. We don't have it clearly stated when costs apply and don't apply in this situation. Some refinances such as this were charged and some refinances were not charged. There was nothing to indicate that this was done on a prohibited basis so for Reg B, I think we're ok. I'm not sure how to include these findings in my report when the focus was Reg B and prohibited basis. Do I note UDAAP concerns or concerns that this has the potential to violate Reg B prohibited basis rules.

One very important concept with any fair lending review. Make sure it is approved at the highest levels of management and before the review starts, determine what the bank is going to do in the event there are any issues. It is not like a HMDA review where the bank can refile if the exceptions are XX% or higher. Higher pricing to a protected class not based on risk or other identified, non-bias criteria, can lead to a referral.

One way to start is get the FFIEC Interagency (or OCC's http://www.occ.gov/publications/publicat...%20Handbook.pdf) Examination Manual, and start looking at what the regulators do. There are tests for compliance, marketing, steering, pricing, etc.

Remember, that your reports are also subject to regulator review, and potentially you gave them a starting point to look. Using the OCC's guide (as a guide) look at Appendix "H" "Appendix H: Using Self-Tests and Self-Evaluations to Streamline the Examination" It has some good tips.