Do you have a commercial loan rate sheet? If so, do you track exceptions on commercial loans for Fair Lending? We are trying to implement this process but keep getting pushback from lenders that say no other banks are required to do this. Anyone have examples of where examiners asked for this to be tracked on the commercial loans? Any information you can provide is greatly appreciated!

From my experience, evaluating pricing from a fair lending perspective is extremely difficult in the commercial world as most commercial loans are (supposedly) priced based on competition. While I admire your efforts, I'm not surprised you are getting push back. The bankers I have talked with over the years seem to be in the exact situation you are in, as most don't have true commercial loan rate sheet that mirrors a consumer rate sheet.

That said, commercial lenders could be in for quite a surprise if/when the CFPB implements the new data reporting rules for loans to small businesses.

We currently use a rate sheet for commercial loans. While we don't track our pricing exceptions on our system, we do speak to them on the Credit Approval. Any exception needs to be explained. Generally, this is something like a large deposit relationship, large loan relationship, credit or collateral issues (for a higher price), etc.