Regardless of the regulator, Community Reinvestment Act and fair-lending examinations are growing in sophistication. When these exams started, denial rates were the focal point.
We hear less and less about denial rates as the regulators have become more advanced in their thinking about discrimination testing. At this point, prudent financial institutions can no longer wait for the examiners to ask questions based on the results of their pre-exam and inbank performance assessments. They must anticipate regulatory questions by doing these analyses before the regulators arrive.