An effective fair lending compliance program can require that a bank’s model risk management and legal and compliance departments meet to review the organization’s inventory of models.
Who at the table is challenging models and steering fair lending? If the model review process doesn’t incorporate a fair lending compliance program, it could have unintentional consequences on deposit and lending portfolios.
And if such meetings are already taking place, it’s beneficial to look at when. Timing a fair lending review earlier in the model process can help optimize the overall schedule and resource use.