Fair Lending Policy Statement for Insured Depository Institutions
Summary
This template of fair lending policy statement is prepared for use by depository institutions insured by the Federal Deposit Insurance Corporation (FDIC) or the National Credit Union Share Insurance Fund that are subject to the supervision and regulatory examination authority of the federal bank regulatory agencies. This template includes drafting notes and optional clauses. The objective of this draft statement of policy is to provide a fair lending policy statement for commercial banks, savings associations, and insured depository institutions subject to state and federal regulation which can be shared on the bank or credit unions website to re-enforce the institutions commitment to the principles of fair lending. Additionally, this policy statement can provide the basic framework for an operational policy, but it is not comprehensive as regards specific products or services, roles and responsibilities, or record keeping and reporting requirements which can vary significantly from institution to institution. This template should be used in coordination with specifics found in the FDIC Consumer Compliance Examination Manual – March 2021 Section of Fair Lending Laws and Regulations can be found here. For a full listing of key materials necessary to develop consumer-related bank policies and procedures central to regulated depository institution operations, see Developing Bank Policies and Procedures Resource Kit. For a full listing of related fair lending content, see Fair Lending Regulation Resource Kit. For related information regarding fair lending requirements regarding consumer credit products see, in relation to residential mortgages, Fair Lending Guidance and Disclosure Requirements for Residential Mortgages and Fair Lending Laws and Enforcement Trends; for student loans see Consumer Financial Regulatory Issues in the Student Lending Market; for credit cards see Fair Lending Considerations Related to Credit Cards and Consumer Regulatory Issues for Credit Cards; and for automotive financing see Consumer Protection in Automotive Financing. An overview of the principal federal fair lending laws and implementing regulations can be found in Fair Lending Regulation Resource Kit.