January 2021 AccumeView: Executive Cybersecurity Pulse Newsletter
The headline is startling: Cybercrime costs the world more than $1 trillion, a
50% increase from 2018. From our experience in the trenches, this feels
about right. Attackers are using more complex methods for spreading their
malware, and the payloads keep getting more sophisticated – better at
evading detection and more effective at delivering their malicious payload.
However, this is just the surface. The article delves a little deeper into the
hidden costs, which most don’t account for when preparing for an incident:
performance. Any major incident not only impact production systems and
operations, but the impact to performance has a lingering effect that most
don’t take into account.
January Monthly Compliance Newsletter
The Fair Lending Risk Assessment – The Finale
The fair lending risk assessment is an integral component of and the springboard for your fair lending program. It is a critical risk management tool that enables the institution to identify and measure the risk inherent in the institution, measure the risk inherent in the bank’s lending s lending processes and to determine what control and
processes and to determine what control and monitoring mechanisms are in place to protect monitoring mechanisms are in place to protect against illegal discrimination.
Why do I need to do a risk assessment?
As with all risk assessments, the intent is to identify the inherent risk (risk without internal control) and to evaluate the control mitigants to determine their effectiveness in addressing the inherent risk. Residual risk is the remaining risk that the institution must review to determine if it is acceptable to the institution or if it is indicative of additional gaps in the lending process that require further mitigation. The institution’s fair lending program is built from this foundation.
So where is fair lending risk hiding in my institution?
Fair lending risk can occur throughout the lifecycle of the lending relationship and is typically due to policies and practices which may be overtly discriminatory; application of a nondiscriminatory policy that has an inadvertent discriminatory effect or the use of discretion in the lending function relative to a prohibited bases with adverse impact. It is also important to include any affiliates or subsidiaries which are part of the lending process and lifecycle.