Training should be not only for those in the lending department, but managers, anybody who deals with any aspect of lending, but also credit union management and board members, because they have responsibility for policies and procedures and what happens in the credit union. Hey everyone, this is Mark with a special Archive episode of With Flying Colors. I hope you enjoy. Do you wanna maximize your success with NCUA?
Join Mark Trico as he shares with you the insider's view on passing your exam with flying colors. The With Flying Colors Podcast is sponsored by Credit Union Exam Solutions by Mark Trico. If you would like to work directly with the Credit Union Exam Solutions team and receive support to optimize your results with NCUA, so you save time and money, visit us@marktrico.com to find out more. Hey everyone, this is Mark TriCal. Thank you for joining me for this episode of With Flying Colors.
I'm excited today that I am joined by Joe Goldberg, a member of my team and the team here at Credit Union Exam Solutions. Joe, welcome. Hi, Mark. Thanks for having me. You bet. My pleasure. So, Joe, for people who aren't familiar with what you did at NCUA and perhaps before NCUA as it relates to credit unions, why don't you share that with us? The real short version is I graduated from law school in 1980, practiced law in a lot of different ways, doing different things for a long time.
Among those, I was in the Pennsylvania Attorney General's Office, Bureau of Consumer Protection for almost 7 years. Where I kind of took a deep dive into consumer protection matters. I came out, among other things, I taught consumer law as an adjunct professor, and eventually in early 2014, I joined NCUA in the, what was then the Office of Consumer Protection in the Division of Consumer Compliance Policy and Outreach.
After a couple of years, I became the director of the division and stayed there doing consumer compliance work, including fair lending work. Until I retired in December of 2021. Very good. You're joining a big cast of care who've left NCA recently. A lot of people hit that point in time where it's time to do something else. And I'm glad that you're out here now assisting credit unions more directly.
So today we're going to talk a little bit about fair lending and a fair lending one on one, if you will. So. So, NCOA has a lot of examiners that do exams, and then there's a structure about fair lending exams and things like that, and that was housed in your office, but before we kind of get into that, let's just start with, when someone says fair lending, what does that mean?
There's no formal definition of fair lending, but in essence, it's a system that requires Decisions on applications for credit to be based solely on credit related factors, not on factors that are unrelated to creditworthiness and are discriminatory. So fair lending is usually looked at by what is prohibited rather than what is required. There's an example on HUD's website, HUD's Department of Housing and Urban Development, which oversees the Fair Housing Act.
Here's what it says on its website for consumers. What is fair lending? Fair lending prohibits lenders from considering your race, color, national origin, religion, sex, familial status, or disability when applying for residential mortgage loans. Fair lending guarantees the same lending opportunities to everyone. We'll see also that in addition to that, that fair lending is designed to enhance the availability of credit.
As I mentioned, I had been an adjunct law professor and when I would teach different laws and regulations, I'd always like to see why were the laws created? What's the purpose of the laws? And fair lending is one of those subjects where that's generally contained right in the laws themselves. There's language in them that says why Congress passed the law. For example, the Equal Credit Opportunity Act, which is probably the main fair lending law, says this right in the statute itself.
The Congress finds that there is a need to ensure that the various financial institutions and other firms engaged in the extensions of credit. exercise their responsibility to make credit available with fairness, impartiality, and without discrimination on the basis of sex or marital status. Now, as an aside, the original ECOA only covered those two prohibited bases, sex or marital status. But then Congress went on to say a little bit more.
It says economic stabilization would be enhanced and competition among various financial institutions and other firms engaged in the extension of credit would be strengthened by an absence of discrimination on the basis of sex or marital status, as well as by informed use of credit, which Congress has heretofore sought to promote. In the Fair Housing Act, there is language that says this.
It is the policy of the United States to provide within constitutional limitations for fair housing throughout the United States. And then in HMDA, the Home Mortgage Disclosure Act, this is a statement of findings. The Congress finds that some depository institutions have sometimes contributed to the decline of certain geographic areas by their failure pursuant to their chartering responsibilities. To provide adequate home financing to qualified applicants on reasonable terms and conditions.
That's kind of a direct reference to redlining, which I'll talk about a little bit later. And then it talks about the purpose of the chapter, which is to provide data and other information to those who are interested in making sure that housing financing is extended on a remuneratory basis. Just one quote I like, it's from President Lyndon Johnson, when he proposed the Fair Housing Act, it was part of the Civil Rights Act of 1968, which was I think the second one, the first one was in 64.
But he said this, I am proposing fair housing legislation again this year, because it is decent and right. Injustice must be opposed, however difficult or unpopular the issue. So that's sort of the long answer to your question. What is there? There's a lot of meat there. Let's unpack it a little bit in a second. I'm going to ask you why this is important. But before I get to that, that quote is great. I love quotes and the finding of Congress, when you highlighted that on redlining.
As you're reading through and discussing all of these things, I'm thinking, okay, that is why N. C. U. A. has the office that you worked for. That is why N. C. U. A. goes out and does. A certain number of fair lending examinations. I want to say somewhere between 25 and 30. We can get into a little bit of that and how those things work. But before we dive into what this means for credit unions specifically, and how it works with NCA, explain a little bit why these laws are so important.
There's two reasons. One is what I just described, which is that the right thing to do is to prevent injustice, but it's also because for those of you listeners who are responsible for consumer compliance. Involved in lending consumer lending, especially, you need to know what the law is, because it can affect the viability of the credit union. So, the laws and these regulations that I'm going to discuss that are fair lending related, they tie into some very important credit related concepts.
We're not talking just about mortgage lending here, because the fair lending laws also apply to other types of credits, such as auto lending, credit cards, and personal loans. They're pretty wide ranging. So some of the policy issues that consider when you talk about fair lending are, number one, the availability of credit, which ties into financial inclusion. Not just a credit union issue.
That's kind of a social issue, as we've learned, especially in the last few years, that it affects equality in credit terms. It tries to ensure that, as I mentioned earlier, as a law state, that credit is extended solely based on credit related factors and no other aspects that aren't credit related. And then I talked about redlining and you had mentioned it, Mark.
Just so you know, this sounds like it's ancient history, but unfortunately, there still are issues with redlining, and it's really important for credit unions to know about this. And I'll talk about that in a second. But redlining, just a little refresher, is a method of excluding properties in a specific geographic area from eligibility for mortgage loans. It can also be affected by who the borrower is.
There are racial implications in borrowers were African American, they would be at a disadvantage and it was used to actually perpetuate segregation and deny African Americans the ability to improve their financial standing and achieve wealth. Through home ownership, the way that non African Americans could, and unfortunately, this was actually a government policy, federal housing administration no longer exists in the way it was originally, but had an underwriting manual.
There was a quote from that underwriting manual that says that incompatible racial groups should not be permitted to live within the same communities. And this is an official US policy. The Federal Housing Administration used color coded maps, and in those maps, the red zones were considered to be hazardous, and generally, communities which were predominantly African American were in those red zones or were those red zones.
There are instances where the manual required walls to be built between neighborhoods. And obviously this is no longer official government policy, but there are remnants of this that affect predominantly people of color and the values of their properties. Generally, credit unions have a different analysis of their lending when determining whether they're involved in redlining.
And there are some people say that credit unions cannot redline because of the field of membership issue that forms a basis of their customer base, the members. But let me just throw this out at you because it's a real life example. A credit union that is chartered to allow as members, people who live or work within a specific specified metropolitan area and the surrounding counties. And this particular credit union does not have any branches in the metropolitan area.
It's a major metropolitan area. And the majority, I should say the largest number of majority minority neighborhoods are in that metropolitan area, as opposed to surrounding areas. So the question can be asked if the credit union does not have a physical presence where the minority applicants are, or most of them, can it redline?
I'm not going to answer the question, because there's a lot of factors that go into it, but I'm just throwing it out there because it's not a simple yes or no. Pause there for one second. So when someone expands into a community that in part would explain by why NCUA requires them to establish a presence or define when they're going to establish a present as part of their business plan, because obviously, if you're expanding to include an area, you should provide service to that area.
And you can get into the whole concept of most or a lot of banking happens on phones. Well, there are a Areas and there are people who need to have branches in order to conduct business. I guess even I said another way, a lack of action to have a branch somewhere could be perceived as a violation. Is that an overstatement or is that actually something that you would agree with? I would agree with that. Yeah, I think you touched on something.
Obviously the world is changing and the way that people interact with financial institutions is changing, but I think the credit union system has grown up on being community based. You know, that without being physically present, that can have an effect on how your lending is dispersed. Yeah. Who you can serve. It was sad to hear what policies were in government as recently as the 1950s. And I think if I heard you right, you said they had actually defined red zones.
And I'm, am I right to assume that it was those red zones that may have led to the phrase redlining? Yes, absolutely. Okay. Got it. There's other issues too, which have come to light recently. There's a presidential initiative around appraisal bias and ways to counteract appraisal bias.
Unfortunately, and this is tied into the redlining because whole neighborhoods may be subject to Appraisals that lower property values and they're self perpetuating actually has a regulation regarding appraisal accuracy and it imposes obligations on credit unions to make sure that appraisers that they use are providing appraisals that are based on. non discriminatory matters or factors.
But anyways, the reason I mention all this is, again, it sounds like ancient history to some extent, but it really is not. It's something that it's important to guard against. Another reason why all this is important is because non compliance creates risks to credit unions.
You can set aside all those policy issues, but all these laws and regulations I'm going to talk about generally have some type of enforcement provision for regulators, including the NCUA, but also they provide for private actions, including class actions. So, there's all several different types of risk are implicated with or for non compliance with fair lending laws. very much. So, I'm a credit union. I'm doing every type of loan that you can imagine. I'm a community charter credit union.
I've never had any issues with the normal exams, but NCUA has the authority to come in and do a specific fair lending exam. And that was the group that you were in charge of at NCUA. And there are some authorities that NCUA has. There's some authorities, I believe you said that DOJ has, and then Housing and Urban Development or HUD. Am I interpreting all that right?
And then along those lines, if you were running a credit union, and you were wanting to be ahead of the curve on NCOA coming in and poking around and taking a look at this whole arena, what would you do if you were out there running a credit union? Well, if we can wait for a few minutes, I got it. I want to talk about, I want to talk about that after I talked about the laws because it'll detail nicely into it.
But yeah, there are things that the credit union should focus on and can do to help protect itself. So, let's talk about the laws and regulations that are involved with this. As I mentioned before, the main one is the Equal Credit Opportunity Act. It's a federal law. ECOA is the acronym for those who are familiar with acronyms. And the Equal Credit Opportunity Act prohibits discrimination in any aspect of a credit transaction.
And it applies to a wide variety of extensions of credit, including extensions of credit to small businesses, And also the corporations, partnerships and trusts under certain circumstances. So there are two major requirements in ECOA. The first is that it expressly prohibits discrimination in any aspect of a credit transaction based on a list of prohibited bases. And these are race or color. And this terminology is from ECOA.
Race or color, religion, national origin, sex, marital status, age, and that's provided the applicant has the capacity to enter into contracts generally 18. The applicant's receipt of income be derived on from any public assistance program and the applicant's exercise in good faith. Of any right under the Consumer Credit Protection Act, that's to prevent retaliation for an applicant who has asserted certain rights. That's the first major requirement of a COA.
This podcast is too short to go into all the excruciating details. But I do want to at least mention that that's the basis for it. The 2nd, major requirement is that a creditor. Must provide applicants with the reason for any adverse action and what adverse action means is a denial of credit that was applied for, or a denial of credit under the terms.
Applied for so if an applicant applies for a mortgage that's advertised at a certain rate, some type of term and the creditor counters and says, you don't qualify for that. But here is a less favorable set of terms that you qualify for. Not necessarily discrimination, but this must be disclosed to the applicant, the adverse action notices, the colloquial term for the disclosure of information. I just want to mention that the Dodd Frank Act created a new section in ECOA.
And that requires the collection of data from applications for small business credit. And in fact, CFPB has issued a proposed rule about what data would be collected and how it would be collected. But nothing's going to happen until that becomes a final regulation. But I did just want to mention that. And as you raised Mark, ECOA does provide for enforcement by regulators and it provides the right to bring private lawsuits, including class actions.
Generally, the N. C. U. A. is the enforcement agency for federal credit unions. And the states or the Federal Trade Commission were named as the enforcement agency for state charter credit unions. Most of you probably know that the CFPB is responsible for enforcement of the larger financial institutions, those with over 10 billion dollars in assets. I don't want to get into that, but generally speaking for federal credit unions, the NCUA is the primary enforcement agency.
And one other thing that you mentioned, the Department of Justice. It has certain enforcement authority, but the equal credit opportunity act requires. The regulators, including the excuse me to refer to any financial institution. It regulates. Where it uncovers a pattern or practice of discrimination, that's a requirement. It's not discretionary. Right. So then when that happens during a fair lending exam at NCOA where you've determined that that's happened, NCOA must refer to DOJ. Correct.
One other thing before we go on. So ECOA establishes, as you stated, expressly prohibits discrimination based on race or color, religion, national origin, and the other items that you went through. When I think back to my examiner days, a phrase someone once said is, you can discriminate based on income. And that's where you get the debt ratios. And that's where you get the ability to repay and things like that.
The list of the things that ECOA protects people from being discriminated against, it makes sense. When you look at them, you want to treat people fairly in all of these areas. Do you have any comments relative to the statement? You can discriminate based on income. First of all, you have to determine whether or not it's discrimination, quote, I mean, this gets into a legal analysis. If it's not listed, then is it really discrimination? I agree with you.
You obviously can use credit related factors and making that credit determination and income is one. It's used all the time. What I should mention is there are essentially two different types of discrimination. Disparate treatment, which is where you would provide all people with a certain prohibited, within a certain prohibited basis, you treat them differently. And age is one that is probably most common. You're not supposed to discriminate based on age.
When I was at NCUA, my people found a number of credit unions who had different age thresholds. For certain types of credit or terms or how they were evaluated and that is disparate treatment. Let's pause there. So let's use me as an example. I'm not quite this age, but let's say I was 65 and I'm still working and I want to get a 30 year mortgage. You might have policies that were written theoretically that.
Might have given better opportunities to someone a little younger with the theory that a 30 year loan for a 65 year old like me isn't necessarily a risk, but they're also presupposing that I'm not going to work till 75, 85. Am I in the right arena of what you're thinking there? It gets a little dicey when you start talking about that. There are some exceptions, if you will, when you're dealing with the adequacy of collateral and those types of things.
But generally speaking, that would be discrimination depending on how things are worded. I should also mention that ECOA does permit creditor to treat older people differently if there is a benefit to them in the way they're treated. But that's a different issue.
So a credit union could have no ill will, could have no intent, but just by having worded things in a certain way, could be creating a situation where there's discrimination, even though all their intent is good, they just chose to write the policy in a way that if you step back and looked at it, could be discrimination. You're exactly right. Intent is not an element of violating ECOA.
To complete the thought, the second type of discrimination is what's called disparate impact, where on its face the rule treats everybody the same, but the result is that some group in one of these prohibited bases ends up on the short end of the lending. They get overwhelming majority, get credit under different terms. And then the question is whether there was any kind of business justification for what was happening.
It's to eliminate discrimination that is not overt, but occurs because the terms or the conditions for the extension of the credit are done in such a way that they improperly affect the people in that group.
Let me give you an analogy from the concepts of disparate treatment and disparate impact, stepping aside from fair lending, and I'll give you an analogy where I'm going to try and build in what you referred to as the business purpose from some things that I learned in my previous life at NCUA. So, the research I did relative to disparate treatment and disparate impact.
Gave an example of being a fireman and if a fire department could establish that fireman, but or fire woman using the fireman as covering everybody needed to have the ability to carry. 30 pounds of equipment, 60 pounds, pick a number, a reasonable number that they had to carry that up X number of flights of stairs, because odds are that's what that person is going to have to do at some juncture that would establish the business purpose for having that requirement. And on average, a male fireman.
Theoretically is going to have a better and easier ability to carry that weight, perhaps, but that if it is set up in a sound fashion, that is a business purpose where you might have disparate impact where people succeeding that test to get into the door to be a fire person. That could create disparate impact, but it would not necessarily mean that it was disparate treatment. Is that a corollary to what we're talking about here in Fair Lending? Yeah, I think it's analogous.
There's some deeper analysis that would probably have to be done in a Fair Lending context, but yeah, but that's essentially a good way to explain it. The threshold and the burden of proof might be higher in Fair Lending. Probably, yeah. Very good. Back to where you were. Okay. I should have mentioned that ECOA was implemented by Regulation B. That's a boy. So you're looking for the regulation that contains more details. It's Regulation B. Now, the second law is the Fair Housing Act.
As I mentioned a little bit before, and in conjunction with Lyndon Johnson, and that prohibits discrimination in all aspects of residential real estate related transactions, and that includes loans for buying, building, repairing, or improving a dwelling, purchasing real estate loans. Selling, brokering, or appraising residential real estate, unselling, or renting a dwelling. And the Fair Housing Act also has a list of prohibited bases, but it's different than E. Coli, it's shorter.
It's only race or color, national origin, religion, sex, menial status. And handicap, but you should keep in mind that ECOA also applies to mortgage related transactions. So, even though a transaction might not fall under the Fair Housing Act, it could still fall under ECOA. So, just something to keep in mind, and the regulations for the Fair Housing Act are promulgated by HUD, and it's enforced by HUD and the Department of Justice, and it also allows for private actions.
And then the third major law that relates to fair lending is, as I mentioned before, HMDA, the Home Mortgage Disclosure Act. That requires financial institutions and that includes credit unions to compile and disclose data about home purchase loans, home improvement loans, and refinancings. They originate or purchase or for which they receive applications. So it doesn't have to be account summated transactions relating to applications.
And the purpose of HMDA is to provide the public with data that can be used to help determine whether credit unions are serving the housing needs of their communities. We're all creditors, not just credit unions, but also it's to assist public officials in distributing public sector investments. So, as to attract private investment to areas where it is needed. And also to assist in identifying possible discriminatory lending patterns. And enforcing compliance with anti discrimination statutes.
It covers, depends on certain thresholds being met in terms of lending activity. Again, there's way too much detail on HMDA to cover it here. Probably be a good subject for another session. And finally, HMDA is implemented by Regulation C, as in CAT. Originally, it was a Federal Reserve Board regulation. It's now a CFPB regulation. And just let me just mention a couple of other laws and regulations that are important.
I did mention the NCOA non discrimination regulation earlier, but actually I mentioned the appraisal regulation. The non discrimination regulation prohibits discrimination in real estate lending and in real estate appraisals and advertising by federal credit unions. I also want to mention. Two other laws, which are sort of lumped together with fair lending laws, even though technically they are not one is the service members civil relief act or and the other is the military lending act.
The service members civil relief act applies to certain transactions generally entered into before the onset of active duty. The Military Lending Act applies to certain transactions that are entered into by active duty service members or their dependents. And although I did say a second ago that they are technically not fair lending laws or regulations, that's sort of not true in some states. Because there are some states that actually have anti discrimination laws.
That include a prohibition against discrimination on someone based on military status. So, you could have lending to service members be a fair lending matter in certain states. And I'm going to talk about that in a minute when I talk about what the credit unions need to do to protect themselves. Let's kind of jump into that. That's where I was going straight for that about 15 minutes back. And now we're about to get to that. So if you were out running a credit union, what would your focus be?
And how would you do your best efforts to protect members and to protect the credit union? Sure. All right. Well, the very first thing is whoever's going to be in charge of consumer compliance or fair lending would know the law and to be an expert in the law, but they need to read it. And the regulations so that they understand that if something happens, a light bulb will go off. Ah, I think I remember there's something in the Fair Lending Act or in HMDA. I better go look at it to see.
So, knowing the law is very important. And that ties in to the second thing, which is That the credit union should have a robust compliance management system. The consumer compliance management system is important because that affects those transactions dealing with members. There is no requirement that the CMS has separate policies and procedures for fair lending. When I was at NCUA, we recommended that credit unions do.
Because Of the significance of fair lending, what it means to credit unions members, you're better served and the members will be better served. It's a separate fair lending policy so that those in the credit union who deal with fair lending are very clear about their obligations. Part of a robust CMS is adequate training.
Training should be not only for those in the lending department, but managers, anybody who deals with any aspect of lending, but also credit union management and board members, because they have responsibility for policies and procedures and what happens in the credit union. There has to be adequate oversight within the credit union. Over the lending practices, so that if there is issues with fair lending, management will be able to see them.
And finally, the last thing is oversight over third parties that the credit union deals with. Indirect lenders who the credit union has relationships with, especially car dealers, because auto financing is troublesome, can be troublesome on several different levels. But also vendors, the people who are creating the systems that the credit union is using for lending purposes, you need to have an understanding of generally how they work.
You don't have to know how the programming works or the code. Yeah, you do have to have some understanding about that. A lot of great ideas as you walk through those, I can highlight that you and I might need to do some separate podcasts on several or all of those specific categories from knowing the law to CMS, to training, that's something I'm looking forward to maybe doing a deeper dive on sometime in the future. That would be helpful. I think you're right. All right.
I've got just two other points when I do want to talk about NCUA's fair lending program that you mentioned before earlier, Mark, the Office of Consumer Financial Protection and actually the division that I was head of the Division of Consumer Compliance Policy and Outreach runs the fair lending program in the NCUA. There are dedicated examiners to conduct the full fair lending exams. There had been 30 a year, the board approved the hiring of a couple of additional fair lending.
Personnel for this year, so that number is probably going to increase and in addition to those full blown fair lending examinations. There are also what are known as supervision contacts prior to those were considered to be off site as opposed to the onsite examinations. But they are a little bit more targeted, they're not as lengthy, and they are often based on analyses of the HMDA data that we talked about a little bit earlier.
In addition to those dedicated fair lending exams and supervision contacts, pretty much every year, field examiners who are doing the general exams of credit unions are also looking at several consumer compliance areas.
And generally each year there are some fair lending aspects to those targeted review areas for 2022 in the NCUA supervisory priorities letter, it says that examiners will identify fair lending policies and practices that indicate discrimination risk or loan portfolio and underwriting discrimination risk. In addition, examiners will assess whether a credit union has policies and procedures to evaluate the consistency, fairness, and accuracy of the appraisals it obtains.
So that's sort of general description of the targeted fair lending reviews at all exams this year. That's a great summary. Let me kind of paraphrase. Correct me if I misstate anything. So the, the standard exam that credit unions are used to seeing. Generally speaking, the priority letter that you referred to are the topics that those examiners may have some discussions with the credit union during the contact. And then within the office that you worked at, there's the fair lending exams.
And the supervision contacts, and it sounded like the supervision contacts, if I heard right, could come from looking at data. So at there's some analysis of the data that may trigger a supervision contact, which is more of a, maybe a rightful approach of a contact.
And then there's the full fair lending exams, and am I right or wrong to assume that those fair lending exams, that might be where it's a random sample where NCUA comes up with who won the lottery and who's going to get a fair lending exam, that would be more of a random sample that wouldn't necessarily been driven by any data. It depends. Each year, the agency would look at anything that field examiners may have found when they were in during the previous year.
Occasionally, we'll get information from whistleblowers. There is information that was obtained from other either states or other federal agencies. It wasn't totally random. In addition to, excuse me, and there could have been information that was obtained during the supervision contact in a prior year. So some of those fair lending examinations are based on information obtained that indicated there could be a fair lending problem.
In addition, there was a desire to look at some of the larger credit unions and possibly some of the smaller ones. So it was not quite random for those who weren't there because there was some information obtained, but to some extent, yes. Okay, got it. So, Joe, if someone was wondering what the best resources out there on the World Wide Web for wanting to study this area, enhance their operations in this area, where would you refer them to?
The first thing I would look at if you're federally insured credit union would probably be the NCOA Fair Lending Guide, which is on the NCOA's website. And there is also what's called the NCOA Federal Consumer Financial Protection Guide. That guide contains pretty much all of the interagency approved Examination procedures. So those 2 resources will help. I can tell you that the NCUA Fair Lending Guide was undergoing updating and some revisions at the time that I retired at the end of last year.
So, at some point, there will be a new version of that, but those 2 things are very helpful. The FFIEC, Federal Financial Institution Examination Council, which is a group of the federal regulators, and the FFIEC, Federal Financial Institution Examination Council, which is a group of the federal regulators. is responsible for collecting hum the data. There are a number of hum the resources on the FFIEC. gov website.
And then the CFPB, the Consumer Financial Protection Bureau has a lot of both fair lending and hum the resources on its website. And finally, for those of you who receive the The NCUA regulatory alerts and letters to credit unions. I would recommend looking at those. They're all archived on the NCUA website, but every year there are several regulatory alerts here to HMDA and occasionally there will be one or two dealing with federal lending as well.
Those would be the primary resources I recommend credit unions use. There's a lot of good nighttime reading there, I'm sure. So two things, if there's some easy to find web links that you want to send me, I can put them in the show notes for this episode. So that someone who's listening on their laptop might be able to go there and find it. And then lastly, before we wrap with this episode, is there any final words that you want to share with the audience?
I think that, from my experience, credit unions as a whole do a really good job with fair lending. The attitude of most credit unions is that they are there to help their members. I would say that the majority of the problems, the overwhelming majority of the problems that with fair lending that were uncovered while I was there, not out of intent as you mentioned, but it was out of ignorance of the requirements of the several laws.
And probably over reliance on vendors of lack of training and those types of things. That's why I mentioned the compliance management system requirement. Credit unions try to get it right, but they don't always do that. The more they can educate themselves, the better off they will be and the better off their members will be. That's a great summary, Joe. All right, well, Joe, I want to thank you for being available here for me and for credit unions. And that's a wrap, folks. That's it for today.
I'm Mark Treichel and I hope you join me next time for With Flying Colors. Thank you for joining us on this episode of With Flying Colors. Subscribe on your favorite podcast app to hear future episodes where subject matter experts of all varieties will provide tips on how to achieve success with NCUA. If you would like to learn more about how we assist credit unions, check out our services at marktreichel. com.