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Fair Lending - Teller Addendum

Updated over 2 weeks ago

πŸ“˜ Handling Loan Inquiries Fairly at the Teller Line


​Step Type: Scenario
​What learners will learn: How to respond to customer loan inquiries without discouragement or bias.
​Step Description: Tellers often serve as the first point of contact for loan applicants. This step provides practical guidance on ensuring every customer receives consistent, non-discouraging responses when asking about credit products.
​Summary of Content: Proper handling of loan inquiries; ECOA requirements; avoiding words or behaviors that may deter protected classes; ensuring equal encouragement to apply.
​Key Topics Covered:

  • ECOA discouragement prohibition

  • Equal treatment in providing information

  • Consistency across customer interactions

πŸ“˜ Escalating Suspected Discrimination

Step Type: Text
​What learners will learn: Teller responsibilities when they observe or suspect discrimination in lending.
​Step Description: This step outlines escalation procedures to compliance or management when a teller notices potential violations of fair lending standards.
​Summary of Content: Escalation triggers; confidentiality protections; avoiding retaliation; documentation of observations.
​Key Topics Covered:

  • Escalation chain of command

  • Confidentiality of reports

  • Prohibition on retaliation

  • Compliance team obligations

πŸ“˜ Recordkeeping and Fair Lending Compliance for Tellers


​Step Type: Text
​What learners will learn: Teller role in ensuring documentation consistency.
​Step Description: This step explains why consistent and accurate recordkeeping by tellers helps institutions demonstrate compliance during audits and examinations.
​Summary of Content: Importance of consistent documentation; prohibited selective documentation; examiner review methods.
​Key Topics Covered:

  • Uniform recordkeeping standards

  • Avoiding selective omission

  • Compliance implications of incomplete records

πŸ“˜ Recognizing Steering Risks at the Teller Window

Step Type: Scenario
​What learners will learn: How to recognize and avoid steering customers toward or away from products.
​Step Description: This step uses scenarios to demonstrate how steering can occur when tellers selectively present credit options.
​Summary of Content: Definition of steering; examples of steering in teller interactions; how to maintain neutrality.
​Key Topics Covered:

  • Definition and risks of steering

  • Equal presentation of options

  • Teller accountability

πŸ“˜ Spotting Redlining Risk in Customer Conversations


​Step Type: Streak
​What learners will learn: How tellers can identify and avoid contributing to redlining concerns.
​Step Description: This step illustrates how customer interactions may raise redlining risks and how tellers should avoid reinforcing geographic bias.
​Summary of Content: Definition of redlining; subtle forms of discouragement tied to geography; how to provide neutral, fact-based information.
​Key Topics Covered:

  • Historical redlining practices

  • Teller interactions with geographic references

  • Neutral responses to customer questions

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