Dear Banker,

Last year we learned that the Department of Justice Attorney General, Meritt Garland, announced an aggressive "Combatting Redlining Initiative." At GeoDataVision we've observed the impact of this action on a growing number of community banks.

However, what came to light this summer in a report from the General Accounting Office is that the Office of the Comptroller of the Currency itself already had initiated several new practices regarding Fair Lending examinations with a very significant impact on Community Banks. Beginning in 2018, the OCC conducted fewer but more targeted Fair Lending examinations of smaller banks. Some of this relates to the impact of Covid. But a consequence of the new practice has been a substantial impact on the incidence of Matters Requiring Attention ("MRA"), which more than doubled from 2017 to 2019 (from 11% to 26% according to the GAO Report).

If you are a community bank regulated by the OCC and have been identified for a Fair Lending exam, your risk of getting a MRA has increased substantially. Among the matters cited in the MRA's is a lack of adequate policies and procedures to monitor and manage Fair Lending risks and the threat of referral to the DOJ for redlining.

We encourage all bankers, and especially community bankers, to review your Fair Lending Risk Management program to make sure you have adequate procedures to identify and report risks to management and your Board. Don't get embarrassed by receiving a MRA as a result of your Fair Lending examination!

If you would like a copy of the GAO Report please click here: