[jeffcumbee]

For years we have been monitoring Interest Rate Exceptions for fair lending purposes, and reporting exceptions to the Board of Directors. Along with the specific exceptions, we have reported the Interest Rate Exception percentage of our total loan volume. My question is, is there any guidance that would tell you if this percentage is acceptable? Are there any industry statistics that could be used to help gauge if a rate of exceptions is excessive? I have searched through the FDIC website and can find where monitoring, documenting, and reporting this information is needed, but there is no guidance as to what would be an acceptable amount (that I can find). I realize that this might vary from institution to institution and market to market, but any help or suggestions would be greatly appreciated. Thanks!

[rcooper]

I consulted with Jack and neither of us are aware of any published standards on this issue. Some examiners may have unofficial guidelines they use.

The level of exceptions will vary among institutions (based on general policy and policy toward exceptions). The important thing is that exceptions are tracked to ensure there is a basis for each and to ensure they don’t favor one consumer over another.

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