Rumor has it: Fair lending exams on the rise

A few weeks ago, I blogged about NCUA’s strategy to examine credit unions for fair lending issues, and the agency’s focus on pandemic-related loan accommodations. However, the rise in fair lending focus is not a pandemic-specific, as it appears the agency has been steadily increasing its volume of fair lending exams over the past few years. However, this does not mean that credit unions have had more fair lending issues.

We have heard from a few credit unions about their experiences with NCUA’s fair lending exams and compared these insights to what NCUA has described in its letter to federal credit union’s regarding its fair lending exam program, which was published in 2013. In short, it appears that NCUA has increased its capabilities and readiness to conduct separate on-site (or virtual) fair lending exams in recent years.

Selection Process

NCUA’s letter states “NCUA will use multiple factors to determine whether a federal credit union demonstrates the potential for higher fair lending risk which could lead to a fair lending exam.” These factors are:


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