📘 Resource: Establishing a Fair Lending Program
Step Type: Text
What learners will learn: Factors to consider when establishing a fair lending program.
Step Description:
Hundreds of pages of regulations, evolving rules and complex nuances mean that managing fair lending compliance could be a full-time job. This resource offers a breakdown for financial institutions when establishing a fair lending program.
Summary of Content:
This step outlines the legal factors lenders may consider when making loan decisions. It also describes the elements of an effective fair lending program, the importance of preventing violations, and common risk factors that may increase fair lending risk.
Key Topics Covered:
Legally permitted lending factors: credit history, income, property condition, neighborhood amenities
Components of a fair lending program: policies, procedures, risk assessments, monitoring, training, complaint tracking
Importance of preventing fair lending violations
Indicators of unmitigated fair lending risk
Common fair lending risk factors
📘 Factors Lenders May Consider
Step Type: MultiChoice
What learners will learn: Factors lenders may consider when deciding to make loans.
Step Description:
Financial institutions may take several legal and objective factors into account when evaluating loan applicants and determining loan terms.
Summary of Content:
This step introduces the lawful criteria lenders can use in assessing creditworthiness and risk. Learners will review permissible factors such as income, credit history, and property value—while also learning what types of information are prohibited. This helps institutions maintain compliance while making sound lending decisions.
Key Topics Covered:
Permissible credit evaluation sources (e.g., FICO scores)
Types of income that may be considered
Economic basis for property evaluations
Legitimate factors for assessing loan terms
📘 Fair Lending Program Requirements
Step Type: Polygraph
What learners will learn: Basic requirements of a fair lending program for financial institutions.
Step Description:
The most effective fair lending programs are tailored to the organization and address all risk factors that may affect that institution.
Summary of Content:
This step reviews the structural components of a compliant fair lending program. Learners will understand the importance of creating policies, monitoring practices, and training that align with their institution’s specific risk profile.
Key Topics Covered:
Core features of an effective fair lending program
Organizational tailoring based on risk
Policy evolution and internal monitoring
Training and complaint management integration
📘 Preventing the Occurrence of Fair Lending Violations
Step Type: True or False
What learners will learn: How to reduce fair lending risks.
Step Description:
Preventing the occurrence of fair lending violations is a core component of an effective fair lending program.
Summary of Content:
This step highlights how institutions can proactively avoid violations through sound risk management and internal accountability. Learners will identify the responsibilities of leadership and operational teams in ensuring compliance.
Key Topics Covered:
Importance of proactive prevention
Organizational responsibility and oversight
Fair lending risk identification and mitigation
Role of compliance across all departments
📘 Fair Lending Risk Factors
Step Type: Streak
What learners will learn: Factors commonly associated with higher fair lending risk.
Step Description:
In establishing a fair lending program, factors which are commonly associated with higher fair lending risk must be identified, assessed and managed.
Summary of Content:
This step trains learners to recognize and respond to factors that elevate fair lending risk. Through real-world examples, it emphasizes how unclear or subjective decision-making, lack of oversight, and third-party reliance can contribute to compliance vulnerabilities.
Key Topics Covered:
Subjective vs. objective decision factors
Policy clarity and justification
Employee discretion and geographic bias
Consumer complaints and third-party oversight
📘 Fostering Fair Lending with Customers
Step Type: Scenario
What learners will learn: How to discuss fair lending with a customer.
Step Description:
Loan decisions are based on creditworthiness, income, and property value—not personal characteristics. A customer is considering applying for a loan but has questions about Fair Lending. Do your part to address their concerns and discuss the policies we have in place to monitor fairness and protect customers from unfair lending practices.
Summary of Content:
This scenario-based step prepares learners to answer customer questions about fair lending with confidence and clarity. Learners will practice reinforcing institutional fairness policies and ensuring customers understand their rights.
Key Topics Covered:
How to address customer concerns about fairness
Communicating institutional safeguards
Reinforcing nondiscriminatory practices
Educating borrowers on eligibility criteria
📘 Mastery Test: Establishing a Fair Lending Program
Step Type: Crossword
What learners will learn: Establishing a Fair Lending Program course review.
Step Description:
Test your knowledge on establishing a fair lending program in this mastery step!
Summary of Content:
This final review reinforces the key concepts of the fair lending program course, including decision-making criteria, policy development, oversight responsibilities, and risk factor identification.
Key Topics Covered:
Definitions: credit bureaus, subjective, economic, violations
Risk-based program design
Oversight and policy review practices
Compliance accountability across operations