Q: What internal controls should be in place regarding fair lending compliance?
A: The credit union’s compliance program should include sufficient internal controls to mitigate and monitor fair lending risk at the credit union. Developing written fair lending policies and procedures, performing risk assessments, and ongoing monitoring of compliance with fair lending laws creates a good foundation for strong internal controls. All of these activities should be appropriate for the size and complexity of the credit union. The supervisory committee and/or internal audit staff should also incorporate an assessment of fair lending compliance in their review programs. NCUA has provided fair lending educational and compliance tools on NCUA’s website at http://www.ncua.gov/Resources/Pages/Fair-Lending-Compliance-Resources.aspx. These tools should help management develop sound internal controls.
This Q&A was obtained from NCUA’s website, in a document entitled “NCUA Fair Lending Examination and Compliance Program for Federal Credit Unions,” which may be found here: