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I’m trying to get some feedback on how (or whether) other banks incorporate Private Banking loan analysis into their Fair Lending reviews. I’d like to know two things:
1. Do you separate Private Banking loans out when doing regression analysis or only do an analysis on your entire HMDA LAR? (We are currently doing both and trying to determine whether necessary as Private Banking loans make up a very small percentage of our total LAR.)
2. How much of a percentage of your HMDA LAR do your Private Banking loans make up? (Rough estimate is fine)
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