The checklist is intended to assist mortgage lenders and servicers in conducting internal fair lending compliance risk assessment. It is recommended that institutions customize the checklist to fit their operations.
The checklist is focused on compliance with federal law requirements. It is recommended that institutions supplement state specific requirements that go beyond federal laws.
“No” response to any of the questions in the checklist may indicate elevated fair lending risk or potential for elevated fair lending compliance risk.
It is recommended that “No” responses be accompanied by a comment that explains the reason and, if applicable, point to a legitimate nondiscriminatory business reason for the practice.
Our Special thanks to our Fair Lending Compliance Checklist Task Force and particularly to the following individuals who worked on developing this Checklist: Solomon Maman, Partner, Noonan & Lieberman, Ltd.; Cassandra Wayman, Fair Lending Manager, Primary Residential Mortgage, Inc.; and Manjari Ganti, Associate Compliance Counsel, Planet Home Lending, LLC.