A fair lending risk assessment is a systematic process that financial institutions use to identify, measure, and mitigate the risk of discriminatory lending practices. If you’re looking to conduct one, here’s what you need to know:

Fair Lending Risk Assessment in 3 Steps:

Identify inherent risk – Evaluate risk factors in all lending stages (marketing, underwriting, pricing, servicing)
Document mitigating controls – Catalog policies, procedures, training, and monitoring systems
Calculate residual risk – Determine remaining risk after controls are applied to prioritize remediation efforts

Fair lending compliance isn’t just about avoiding regulatory penalties—it’s about building trust with your customers and protecting your institution’s reputation.

As the FDIC defines it, a fair lending risk assessment is “an effort to identify and measure the risk inherent in the bank’s lending processes and determine what control and monitoring mechanisms are in place to protect against illegal discrimination.”

The stakes are high. Regulatory agencies like the OCC, FDIC, Federal Reserve, and CFPB actively examine financial institutions for fair lending compliance. Civil money penalties from the Department of Justice typically result in settlements that can be costly both financially and reputationally.

“Completing a fair lending risk assessment is a challenging task as there are many things to consider in a financial institution that relate to the risk of discrimination.”

The good news? A well-structured assessment becomes easier and more efficient over time. By focusing on the three-step process of evaluating inherent risk, documenting mitigating factors, and calculating residual risk, you create a repeatable template that streamlines annual reviews.

Remember: Discrimination can occur at any stage from the moment a potential borrower inquires about a loan until the loan is paid off. Your assessment must cover the entire lending lifecycle.

Understanding Fair Lending Risk Assessment

When we talk about a fair lending risk assessment, we’re looking at a powerful tool that helps financial institutions identify potential discrimination in their lending practices before problems arise. Think of it as your financial institution’s early warning system – designed to protect both your customers and your organization.

The OCC has mapped out a clear six-step process that makes this assessment manageable:

First, you’ll document your institution’s background information. Then assess risk at each product level – because let’s face it, a mortgage loan carries different fair lending risks than a credit card. Next, you’ll identify specific focal points for examination, evaluate your existing management controls, determine if transaction testing is needed, and finally prepare recommendations for future supervision.

It’s worth noting that regulatory oversight varies based on your institution’s size. If you manage a bank with more than $10 billion in assets, the CFPB will supervise your ECOA compliance. Smaller institutions with $10 billion or less will work with their primary regulator, whether that’s the OCC, FDIC, or Federal Reserve.

One of the most challenging aspects of fair lending compliance is recognizing that discrimination comes in multiple forms. It’s not always obvious. You might have overt discrimination through explicit policies (rare these days), disparate treatment where similar applicants receive different treatment based on prohibited characteristics, or disparate impact where seemingly neutral policies disproportionately affect protected groups.

What a Fair Lending Risk Assessment Is — and Isn’t

Let’s clear up a common misconception: a fair lending risk assessment is not the same as a fair lending audit. While both are important, they serve different purposes.

An audit looks backward, examining past transactions to identify violations that have already occurred. A risk assessment, on the other hand, looks forward – helping you identify potential risks before they become violations. It’s preventative rather than detective.

As Ben Henke, a Fair Lending Examination Specialist, puts it: “Risk assessment is about identifying and measuring risk in the bank’s lending processes and determining what controls are in place to protect against illegal discrimination.”

Your assessment revolves around three key components that work together:

Inherent risk exists in your lending operations before any controls are applied. This is the raw, unmitigated risk based on factors like market demographics and product complexity.

Control effectiveness measures how well your policies, procedures, and systems mitigate that inherent risk. Strong second-review programs and consistent exception monitoring can dramatically reduce your risk exposure.

Residual risk is what remains after your controls are applied – this is your actual risk exposure and should drive your action plan.

Here’s a fascinating insight: Most civil money penalties from the Department of Justice for fair lending are settlements, not court-confirmed violations. This means your focus should be on identifying and addressing risk before it escalates, not just responding to obvious violations.

Why Residual Risk Drives Your Action Plan

Residual risk should be the compass that guides your compliance efforts. Why? Because it represents your actual exposure after all your hard work implementing controls. This is exactly how regulators prioritize their examinations, and you should allocate your resources similarly.

I like to explain this using a skydiving analogy. Skydiving has tremendous inherent risk – gravity will pull you toward the earth at about 120 mph. That’s a fact of physics. But with proper controls like a licensed instructor, functioning equipment, and proper training, the residual risk becomes quite manageable. In 2018, Americans completed approximately 3.3 million skydives safely because of effective controls.

Your lending operation works the same way. Yes, there are inherent risks in offering loans – particularly in diverse markets with complex products. But with proper policies, training, monitoring, and testing, you can reduce your residual risk to acceptable levels.

The key is knowing where to focus your remediation efforts. Which areas still have the highest residual risk after your controls are applied? Those are the areas that deserve your immediate attention and resources. This targeted approach not only satisfies regulators but also protects your customers and institution more effectively.

The Legal & Regulatory Framework You Must Know

Understanding the legal landscape isn’t just important for your fair lending risk assessment – it’s absolutely essential. When I work with financial institutions, I often find they know they need to comply with fair lending laws, but aren’t always clear on the specific requirements that shape their risk assessment.

Key Prohibitions Under ECOA & FHA

The foundation of fair lending rests on two primary federal laws – each with its own set of protected classes and prohibitions.

The Equal Credit Opportunity Act (ECOA) casts a wide protective net. It ensures lenders can’t discriminate against borrowers based on race or color, religion, national origin, sex (which now includes gender identity and sexual orientation), marital status, age (as long as you’re old enough to sign a contract), receipt of public assistance income, or exercise of consumer rights under the Consumer Credit Protection Act.

Meanwhile, the Fair Housing Act (FHA) focuses specifically on residential real estate transactions. It prohibits discrimination based on race or color, national origin, religion, sex, familial status, and disability.

Regulation B implements ECOA with specific requirements that get quite detailed. For instance, you can’t subtly discourage certain groups from applying, use different standards when evaluating creditworthiness, change the terms offered based on protected characteristics, or require a spouse’s signature when an applicant qualifies on their own merits.

Let me share a real-world example from the OCC Handbook that illustrates how these rules apply in practice. A bank denied a mortgage to an applicant with a disability because they didn’t properly “gross up” the applicant’s nontaxable disability income. This miscalculation made the debt-to-income ratio appear too high. Had they correctly grossed up the $3,000 monthly disability income at a 25% tax rate, the applicant would have shown a 37.5% DTI – well below the bank’s 40% limit. This seemingly technical error actually constituted discrimination.

How Examiners Scope Fair Lending Risk Assessment

Regulators don’t examine everything at once – they use a risk-based approach to focus their attention where it matters most. Here’s how they typically zero in on potential issues:

The OCC establishes what they call a “focal point” – a specific combination of loan products, markets, decision centers, timeframes, and prohibited bases they want to examine closely. Think of it as their targeting system for potential discrimination.

The Federal Reserve uses Matters Requiring Immediate Attention (MRIAs) and Matters Requiring Attention (MRAs) to flag fair lending concerns. In 2022, we saw state member banks repeatedly cited for failing to conduct proper fair lending risk assessments, skipping fair lending training, incorrectly handling nontaxable income, and maintaining inadequate monitoring systems.

The FDIC approaches examinations through their Assessment of Risk of Consumer Harm (ARCH) process. They methodically evaluate inherent risk, examine your controls, and determine the residual risk remaining in your lending operations.

All regulators pay close attention to complaint trends. A sudden increase in complaints from specific demographic groups in particular areas often triggers deeper investigation. It’s like an early warning system for potential discrimination patterns.

At Concertium, we’ve helped many financial institutions prepare for these regulatory examinations by building robust assessment frameworks that directly address these focal points. We understand how regulators think because we’ve seen how their examination priorities evolve over time.

Building a Rock-Solid Fair Lending Risk Assessment Template

Creating a comprehensive fair lending risk assessment template isn’t just about checking regulatory boxes—it’s the foundation that supports your entire compliance program. Think of it as building a house: without a solid foundation, everything else becomes unstable.

Your template should thoughtfully evaluate every touchpoint in your lending process, from the moment a potential borrower sees your marketing to the final payment on their loan.

A truly effective template includes three essential components:

Inherent Risk: These are the raw, unmitigated risks present in your lending operations—think of them as the natural hazards in your lending landscape.
Mitigating Factors: These are your safeguards—the policies, training, and systems you’ve implemented to reduce those risks.
Residual Risk: This is what remains after your controls are applied—the areas where you’re still vulnerable and need to focus attention.

Your assessment needs to cover the entire lending journey: marketing efforts, application processing, underwriting decisions, pricing strategies, servicing practices, collections activities, and oversight of any third parties involved in your lending process.

Identifying and Scoring Inherent Risk in Each Loan Stage

Every stage of lending carries its own inherent risks. Let’s explore how to spot and evaluate them:

In marketing and advertising, seemingly innocent decisions can create unexpected risk. One bank finded its digital marketing campaign only ran in predominantly white neighborhoods—not because of deliberate discrimination, but because they hadn’t considered the demographic implications of their targeting strategy.

Your marketing risk factors might include geographic targeting that unintentionally excludes certain communities, digital platforms that reach limited demographics, or language barriers that discourage certain applicants from applying.

During application and origination, watch for inconsistencies in how loan officers assist applicants, subjective documentation requirements, or varying pre-qualification practices that could treat similar borrowers differently.

In underwriting, manual override capabilities open the door to potential bias. Complex or subjective criteria and factors with potential disparate impact need careful scrutiny.

Pricing risks often lurk in discretionary rate adjustments, inconsistent fee waivers, and incentive structures that might encourage loan officers to offer different terms to similar borrowers.

Even servicing carries risk—inconsistent application of late fee waivers, varying standards for workout options, or selective communication about assistance programs can all create fair lending concerns.

When scoring these risks, consider the volume of transactions, complexity of your products, level of discretion allowed, demographics of your market, and any history of complaints or violations. A simple 1-5 scale works well for most institutions.

Cataloging Mitigating Factors & Existing Controls

Now for the good news—you likely have controls in place that help mitigate these risks. Your job is to document them thoroughly:

Robust policies and procedures serve as your first line of defense. These should include written guidelines for every lending stage, clear requirements for documenting exceptions, and regular policy reviews.

Comprehensive training programs ensure your team understands fair lending requirements. Document not just the training content, but attendance records and testing results to demonstrate effectiveness.

Second-review programs provide crucial oversight. One credit union dramatically reduced its fair lending risk by implementing automated underwriting rules while maintaining human second reviews for denied applications—a perfect balance of consistency and compassion.

Monitoring systems help you spot potential issues before regulators do. Regular analysis of approval/denial rates by demographic group, pricing disparity reviews, and geographic distribution analysis can reveal hidden patterns.

Board and management oversight demonstrates your commitment to compliance. Regular reporting of fair lending metrics, clear accountability, and appropriate resource allocation all help mitigate risk.

Automated decisioning tools, when properly implemented, can reduce human bias while maintaining appropriate flexibility.

Learn more about our Compliance Risk Analysis services

Calculating Residual Risk and Prioritizing Remediation

Once you’ve identified your inherent risks and mitigating controls, you can calculate what matters most: residual risk. This calculation guides where to focus your limited resources.

Start by creating a simple risk matrix. For each lending area, subtract the effectiveness of your controls from the inherent risk score. The result helps you prioritize your remediation efforts.

Visual tools like heat maps can transform complex risk data into intuitive displays for board and management reporting. These color-coded representations immediately highlight your highest-risk areas.

When prioritizing remediation, focus first on high-risk areas with significant loan volume or potential consumer harm. One regional bank finded through this process that their indirect auto lending program carried their highest residual risk. Dealer discretion in pricing was creating potential disparities. By implementing dealer scorecards and fee caps, they significantly reduced this risk.

For each high-risk area, develop specific, measurable action plans with clear ownership and realistic deadlines. And remember to adjust your testing frequency based on risk—higher-risk areas deserve more frequent scrutiny.

At Concertium, we’ve helped dozens of financial institutions build assessment templates that not only satisfy regulators but actually improve lending practices. The right template doesn’t just identify problems—it provides a roadmap to solve them.

Compliance Risk Assessment: 5 Essential Expert Tips

Implementing, Monitoring & Updating Your Fair Lending Risk Assessment

Let’s face it—your fair lending risk assessment isn’t something you can just file away and forget about. Think of it more like tending a garden than building a monument. It needs regular care to thrive.

Most financial institutions refresh their assessments annually, though some stretch to an 18-month cycle when resources are tight. (We’ve all been there with competing priorities!)

But life happens, and sometimes you can’t wait for your regular cycle. Several situations should trigger an immediate review:

When you merge with another institution or acquire new business lines, you inherit their compliance risks too. Launching new products or expanding into different markets changes your risk profile significantly. And of course, if regulators announce a new focus area or you spot emerging risks internally, it’s time for a fresh look.

Even technology changes matter—a new loan origination system might create unexpected gaps in your controls.

Your monitoring should draw from every available data source. HMDA data gives mortgage lenders valuable demographic insights, but what about auto loans, personal loans, or small business lending? For these, you might need to use proxy methods—like surname analysis or geocoding—to estimate demographic characteristics of your borrowers.

Leveraging Technology and Data Analytics for Ongoing Compliance

Gone are the days of manually reviewing loan files and hoping you catch problems. Today’s fair lending risk assessment process can leverage powerful technology tools that make compliance both more effective and less painful.

AI-powered systems can now spot statistical disparities that might indicate discrimination long before they become regulatory issues. These tools analyze approval rates, pricing decisions, and policy exceptions across demographic groups, giving you early warning of potential problems.

Worried about redlining? Geographic Information System (GIS) tools create revealing maps that overlay your lending patterns against demographic data. One glance can tell you if you’re adequately serving majority-minority areas.

Exception tracking systems have also come a long way. Instead of digging through paper files, automated systems now flag exceptions to standard policies in real-time, ensuring proper documentation and revealing any concerning patterns.

Even third-party monitoring has improved dramatically. API integrations with vendor systems allow you to keep tabs on partner compliance without constant manual checks. And when it comes to customer complaints, natural language processing tools can identify fair lending themes that might otherwise go unnoticed.

At Concertium, we understand that these compliance technologies must be both effective and secure. We help our clients implement monitoring systems that protect sensitive customer data while ensuring regulatory compliance.

Explore our Compliance Risk Management Services

Documenting, Reporting & Satisfying Regulators

When the examiners arrive (and they will), your documentation needs to tell a clear, compelling story about your compliance efforts. Think of it as preparing evidence for a friendly court case.

Your risk-ranking justification should explain why you rated certain areas higher risk than others. This isn’t just about having a methodology—it’s about showing your work so regulators understand your reasoning.

Examiner-ready files save enormous stress during reviews. When an examiner asks for your last three board reports on fair lending, you want to produce them in minutes, not days. Organization matters!

Board reporting should include both executive summaries (for busy directors) and detailed reports (for risk committees). Board minutes documenting discussions about fair lending risks are gold in an examination.

Training logs prove you’re not just talking about compliance but actively building knowledge. Document content, attendance, and—importantly—test results that show learning occurred.

Control testing results demonstrate that your controls actually work, not just exist on paper. Include both successes and failures, along with your remediation plans.

A community bank client of ours avoided a potential Matter Requiring Immediate Attention (MRIA) by presenting a well-documented fair lending risk assessment that clearly showed their methodology, findings, and remediation plans. The examiner specifically noted that the bank’s proactive approach demonstrated a strong compliance culture.

That’s the power of thorough documentation—it transforms your assessment from a regulatory requirement into a powerful demonstration of your commitment to fair lending.

Common Pitfalls and How to Avoid Them in Your Fair Lending Risk Assessment

Let’s be honest – even the most well-intentioned financial institutions can stumble when conducting fair lending risk assessments. It’s a bit like trying to steer a compliance obstacle course while blindfolded. But don’t worry – we’ve seen these pitfalls before and can help you avoid them.

Many institutions have a marketing blind spot in their assessments. They’ll carefully review underwriting and pricing while completely overlooking how their marketing might exclude protected groups. I recently worked with a bank that was advertising exclusively on platforms with predominantly white audiences – not intentionally, but the impact was the same. The solution? Take a step back and evaluate the geographic and demographic reach of all your marketing campaigns, including those sophisticated digital advertising algorithms that might be creating unintended bias.

Discretionary pricing is another danger zone. Giving loan officers freedom to adjust rates without proper guardrails is like handing out matches at a gas station – eventually, something will catch fire. One of our clients finded significant pricing disparities when they finally analyzed their exception data. They quickly implemented clear guidelines for pricing exceptions, required thorough documentation, and set up quarterly reviews to catch patterns before they became problems.

Would you believe that failing to gross up non-taxable income was one of the top Federal Reserve MRAs (Matters Requiring Attention) in 2022? It sounds technical, but the impact is very real. When you don’t properly account for disability payments or child support income, you might inadvertently exclude protected classes. The fix is straightforward: review your underwriting policies to ensure non-taxable income gets the proper treatment.

Third-party oversight gaps are growing more common as financial institutions increasingly rely on vendors and partners. As one banking executive told me, “We spent so much time getting our own house in order that we forgot to check if our partners were following the same rules.” Ask your third parties specific questions about their fair lending programs, review their exception practices, and build fair lending requirements into your contracts.

Training complacency is the silent killer of compliance programs. That annual fair lending presentation from 2019 that everyone still yawns through? It’s not cutting it anymore. Implement fresh, role-specific training that reflects current regulations and real-world scenarios. And yes, test knowledge retention – what gets measured gets managed.

Learn about our Compliance Risk Advisory Services

The “effects test” is where many institutions get tripped up. It’s not about your intentions – it’s about results. Policies that seem perfectly neutral on paper can still create discriminatory outcomes.

Statistical disparities without business justification are enforcement magnets. I recall a community bank that implemented a $60,000 minimum loan amount policy to improve efficiency. Sounds reasonable, right? Unfortunately, this policy disproportionately excluded minority applicants in their market. When regulators applied the effects test, the bank had to scramble to revise the policy and create alternatives for smaller loans.

Age-based credit scoring differences are another surprisingly common issue. One credit union client was shocked to find their policy of providing $750 credit limits for customers aged 21-30 and $1,500 limits for those over 30 was textbook age discrimination under ECOA. Their intentions were good – they wanted to help younger borrowers build credit responsibly – but the execution violated fair lending laws.

Override abuse happens when exceptions become the rule – for some borrowers but not others. In one particularly clear case, a lender approved a White couple after verifying a vacated judgment but denied an African American couple without allowing them to dispute the same credit-report issue. Consistency is your best defense here.

Integrating Past Compliance History & Complaints into Current Assessment

Your fair lending risk assessment should be like a good detective – it needs to consider all the evidence, including historical patterns.

Trend analysis of past MRAs and examination findings can reveal persistent issues that need extra attention. One of our clients finded that they’d received similar findings about their indirect auto lending program across three examinations. This pattern helped them prioritize a complete overhaul of that program in their remediation efforts.

Remediation effectiveness deserves a hard look too. Did those fancy new policies and procedures actually fix the problem, or are you seeing the same issues reappear? Be honest with yourself here – regulators certainly will be.

Complaint analysis is often a gold mine of insights. When done properly, it can reveal patterns that might otherwise go unnoticed. A regional bank client found through complaint review that certain branches were consistently less helpful to minority applicants – not because of explicit bias, but due to staffing and training gaps. This led to targeted training and mystery shopping to verify improvement.

Don’t forget about whistleblower information. Your employees are on the front lines and often see issues before they appear in the data. Create safe channels for them to report concerns about fair lending practices without fear of retaliation.

At Concertium, we help financial institutions weave these historical insights into their current risk assessments. The result is a more comprehensive view of compliance risks that satisfies regulators and protects your institution. After all, those who don’t learn from compliance history are doomed to repeat it – often with larger penalties the second time around.

Frequently Asked Questions about Fair Lending Risk Assessment

How often should our institution update its fair lending risk assessment?

Let’s face it—compliance tasks can sometimes feel like that exercise bike gathering dust in your garage. You know you should use it regularly, but life gets busy.

Most regulators recommend conducting a fair lending risk assessment at least annually. Think of it as your compliance check-up. However, if your resources are stretched thin (and whose aren’t these days?), an 18-month cycle can work too—as long as you’re vigilant about conducting additional reviews when significant changes occur.

These trigger events include:

Mergers or acquisitions (when two lending cultures combine)
New product launches (especially those targeting specific markets)
Market expansions (entering areas with different demographics)
Regulatory changes (when the goalposts move)
Technology implementations (new systems can create unexpected gaps)

As one compliance veteran with a touch of pragmatism told me, “Even an 18-month review is far better than none at all.” Sometimes perfection is the enemy of good enough when it comes to compliance.

What happens if regulators find our assessment inadequate?

Nobody likes to imagine the worst, but it’s good to understand what might happen if regulators find your fair lending risk assessment lacking. Typically, consequences follow a progressive approach—think of it as regulators giving you increasingly urgent nudges toward compliance.

First come Matters Requiring Attention (MRAs). These are like your doctor saying, “You should probably cut back on the salt.” Important issues that need addressing, but not panic-inducing.

Next level up are Matters Requiring Immediate Attention (MRIAs). Now your doctor is saying, “Your blood pressure is dangerously high—we need to address this now.” These require prompt corrective action.

If issues persist or are severe, you might face Formal Enforcement Actions like consent orders. This is the regulatory equivalent of being admitted to the hospital—structured treatment with close monitoring.

In the most serious cases involving potential patterns of discrimination, regulators may refer your institution to the Department of Justice. That’s when things get really uncomfortable.

The Federal Reserve’s 2022 data showed the most common fair lending issues for state member banks included failing to conduct assessments altogether, skipping training, not grossing up nontaxable income, and having weak monitoring systems. These are all fixable problems if caught early!

Can we outsource the entire fair lending risk assessment process?

Yes, you can outsource your fair lending risk assessment—and many institutions do—but it’s a bit like hiring a personal trainer. They can guide you through the process and provide expertise, but you still need to do some of the work yourself.

The benefits are clear: external consultants often spot risks that internal teams miss (fresh eyes see fresh problems), they bring specialized expertise in regulatory requirements, and they offer that valuable neutral perspective on your lending operations.

But remember these important points:

Your board and management remain ultimately responsible for compliance—you can’t outsource accountability. Think of it like taxes—you can hire an accountant, but you’re still signing that return.

Your internal staff should actively participate to build institutional knowledge. Otherwise, you’ll be forever dependent on outside help.

Management needs to thoroughly understand the results. A beautiful assessment report gathering dust on a shelf helps no one.

Remediation plans work best when developed internally with consultant guidance. Your team knows your institution best.

Cost-wise, expect to pay anywhere from at least $1,000 for a basic review to tens of thousands for a comprehensive assessment, depending on your institution’s size and complexity.

At Concertium, our approach to fair lending compliance support recognizes that the best solutions combine our expertise with your institutional knowledge. We help you build a sustainable compliance process rather than creating dependency on our services—because ultimately, the goal is making your institution stronger, not just checking a regulatory box.

Conclusion

A robust fair lending risk assessment isn’t just another box to check for regulators—it’s a vital business practice that protects your institution while building lasting trust with customers and communities.

Throughout this guide, we’ve walked through our proven three-step process: identifying inherent risk, documenting mitigating controls, and calculating residual risk. This framework creates a repeatable system that becomes more efficient and effective each time you use it.

As you move forward with your fair lending compliance journey, keep these essential points in mind:

Comprehensive Coverage matters tremendously. Your assessment needs to examine every stage of the lending lifecycle—from those first marketing touchpoints all the way through servicing. Missing even one area can leave your institution vulnerable.

Focus on Residual Risk to make smart decisions. After all your controls are in place, what risk remains? That’s where you should direct your resources and attention first. Like our skydiving example showed, proper controls make even inherently risky activities manageable.

Regular Updates keep you protected. The lending landscape changes constantly. Annual reviews are the minimum, with additional assessments whenever you introduce new products, expand markets, or undergo organizational changes.

Documentation saves you during examinations. Clear records of your methodology, findings, and remediation efforts aren’t just good practice—they’re your best defense when regulators come knocking.

Technology Leverage gives you an edge. Modern data analytics tools can spot potential disparities and compliance issues before they become problems, creating a proactive rather than reactive approach.

At Concertium, we understand that fair lending compliance is just one piece of your broader risk management puzzle. With nearly 30 years in the field, we’ve developed expertise that spans the entire compliance landscape. Our enterprise-grade cybersecurity services include custom compliance and risk management solutions for financial institutions of every size.

Our unique Collective Coverage Suite (3CS) with AI-improved observability doesn’t just help you meet regulatory requirements—it helps you build a proactive compliance culture that protects both your institution and your customers.

Explore our Consulting and Compliance Solutions

Don’t wait until you’re facing regulatory scrutiny to assess your fair lending risk. Reach out to Concertium today to find how we can help you build a fair lending risk assessment process that’s not only robust and efficient but also supports your broader business goals. After all, good compliance isn’t just about avoiding problems—it’s about creating opportunities to better serve all your customers.