Answer:
We may see more LPOs being established to fill gaps based on branch contractions. As it relates to fair lending, regulators have indicated that LPO locations may be relevant to redlining analyses in some circumstances. Unfortunately we have little guidance in this area and even less with respect to LPO influences on fair lending analysis or indirect product lines. A bank's analysis of the area it serves and resulting loans is key.
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Learn more about Andy Zavoina’s Fair Lending, 2022 is a New Mindset webinar.
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