Independent Banker - July 2019 - 18
PORTFOLIO
Mastering the sixth C
of credit: compliance
Compliance
To boost their community bank's
compliance efforts and build trust with
their regulator, loan officers may find it helpful to think
about their next loan like an examiner would. By Mary
Thorson Wright
A
responsible lending program should cover the six
Cs of credit. You heard that right: six.
Loan officers learn about the five Cs of credit: character,
capacity, capital, collateral and conditions. The sixth
is compliance-fair lending compliance, in particular. Fair
lending compliance goes well beyond accurate paperwork
and checked boxes. It can reflect favorably or unfavorably on
18 Q ICBA Independent Banker Q July 2019
overall management competence and organizational culture.
Community banks must make financially sound loans and
adhere to the letter and spirit of fair lending regulations.
Confirming compliance takes macro and micro analyses
of bank practices much like those performed before and
during examinations, such as board oversight, risk assessment,
training, monitoring, complaints, testing, vendor risk
and lending policies. Is that enough?
Baseball great Yogi Berra once said, " If you don't know
where you are going, you might wind up someplace else. " And
if you don't know where you are, it's tough to know where
you need to go. So, before you begin racing through mortgage
loan files to see if the boxes are checked and to collect con
Independent Banker - July 2019
Table of Contents for the Digital Edition of Independent Banker - July 2019
Table of Contents
Independent Banker - July 2019 - Intro
Independent Banker - July 2019 - Cover1
Independent Banker - July 2019 - Cover2
Independent Banker - July 2019 - Table of Contents
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Independent Banker - July 2019 - Cover3
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