Fair Lending compliance applies to the entire lending process, including the servicing, loss mitigation, forbearance, fees, optional products, and repossession or foreclosure processes. As regulators turn their focus to the scrutiny of loan servicing operations, lenders must ensure they are doing all they can to document and analyze their efforts to assist borrowers. Identifying and mitigating Fair Servicing risk requires complete and accurate data, a clear set of policies and procedures, and thorough assessment of all assistance lenders provide to borrowers.
Fair Servicing Risk Assessments
ADI’s Fair Servicing risk assessments help lenders reduce Fair Servicing risk, identify weaknesses, and implement necessary controls. We provide a clear picture of the comprehensiveness, completeness, and accuracy of the lender’s loan servicing data. Based on our findings, ADI’s consultants offer recommendations for the data and processes required to strengthen Fair Servicing performance and prepare for regulatory exams.
Our Expertise
We help lenders identify and mitigate Fair Servicing risk through:
- Review and assessment of the controls in place to address potential risk
- Statistical analyses of lending data to ensure that loss mitigation solutions, as well as foreclosures, are addressed fairly and in a nondiscriminatory manner
- Policy and procedure review, to develop and implement non-discriminatory processes throughout the lending life cycle
- Comparative file reviews, typically for smaller portfolios, to address servicing issues
- Complaint data review and peer comparison to identify weaknesses and target necessary controls and corrective action.
ADI’s consultants have extensive experience in analyzing data and proposing effective solutions to meet strategic business and regulatory objectives. To learn more about our Fair Lending and Fair Servicing analytics and consulting services, contact us today.