Lexington Lending is committed to serving all borrowers equally, without regard to an individual's race, color, national origin, religion, sex, familial status or handicap. As such, it is Lexington Lending's policy to issue all conditional commitments (to purchase a loan) without regard to a borrower's race, color, national origin, religion, sex, familial status or handicap.
With the goal of Fair Lending in mind, it is also our policy to promote Fair Lending practices to our entire wholesale customer base. Though Lexington Lending does not dictate how a wholesale customer prices a loan or charges fees to a borrower, we must emphasize the critical nature of supporting sound Fair Lending practices.
Lexington Lending urges all of our wholesale customers to develop fair lending procedures that provide controls to determine and guard against originating loans that are in any way biased based on a borrower's race, color, national origin, religion, sex, familial status or handicap.
Bias is not restricted to merely whether or not a borrower receives a loan. Bias may also be demonstrated by analyzing rates and fees charged to borrowers of a specific group. In an effort to ensure that our wholesale customer base is compliant with the Fair Housing Act, Lexington Lending performs regular post-closing reviews to determine if any borrower treatment or pricing disparity exists for borrowers in a specific group (as outlined by the Fair Housing Act).
By reviewing the rates/fees charged on closed loans purchased from our wholesale customer base, our goal is to verify whether any disparities exist. If Lexington Lending determines that disparities do exist for a specific wholesale customer, we may exercise our right to cease conducting business with a specific wholesale customer.
We would also like to emphasize that Fair lending laws do not focus on a lender's "intent." We believe that all wholesale customers "intend" to provide borrowers with loans. Rather than focus on intent, compliance with the Fair Housing Act requires our wholesale customer base to look at their loans and analyze whether all borrower groups are priced/charged and treated equitably.
Though Lexington does analyze rates and fees charged by our wholesale customer base, we would like to emphasize that this practice will not protect you from being pulled into litigation for non compliance with the Fair Housing Act. The best way to protect your business is to adopt sound and comprehensive fair lending procedures. By doing so, we work together in our common goal of Fair Lending for all borrowers.
For your convenience, we have provided HUD's language on Fair Housing as it pertains to our industry: |
