I am looking to benchmark how other institutions structure their fair and responsible banking fair lending review function within three lines of defense model.
Do you house Fair Lending within the second line of defense, and if so, how independent is the team from first line of compliance? I'm also interested in how others define fair lending thresholds for errors. On average are fair lending reviews being done on a quarterly or annual basis? How many target and controls are reviewed during this process?
If you are willing to share, I'd appreciate hearing about your review process, tolerance levels, and any practical approaches that have worked well during examinations.
Thank you in advance for your insights.
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