Have you considered the similarities between fair lending compliance programs and family reunions? Interpersonal dynamics aside, the components of regulatory compliance programs mirror elements of a family reunion, including:
- Parents: Authority figures who provide guidance and enforce accountability for the group.
- Children: Individuals trying to grow, learn, and adapt based on parental guidance.
- Extended Family: Individuals who may play significant development roles and are germane to the family.
- Home: A space where the above individuals spend time together, communicate, and share values.
In relation to family, there is a crucial difference with regulatory compliance programs: organizations can “choose” their family (meaning, the regulatory compliance programs they want). For example:
- Leadership. Federal agencies provide guidance and enforce accountability under such programs. Board and senior management set the tone for a culture of compliance at the top of an organization.
- Employees. Compliance professionals work to develop all employees within the organization to understand, adapt, and maintain compliance in the ever-changing regulatory world.
- Stakeholders. Customers, vendors, regulatory agencies, and board members are part of compliance programs. Thus, institutions must work to ensure they incorporate external parties’ requirements and expectations to help maintain compliance.
- Work Environment. This is the space where policies, procedures, and practices are put in place that reflect each company’s mission and purpose.
With this in mind, the family framework can be applied to a type of “fair lending family reunion,” where the following family members are invited:
- The Equal Credit Opportunity Act (ECOA)
- The Fair Housing Act (FHA)
- The Community Reinvestment Act (CRA)
- The Home Mortgage Disclosure Act (HMDA)
The four “members” above must be included to yield a compliant family reunion. Here’s why.
The ECOA & FHA
The ECOA and FHA can be thought of as the parental figures in this analogy, setting the boundaries and providing equal opportunities for regulatory compliance programs.
The ECOA prohibits creditors from discriminating against applicants based on race, color, religion, national origin, sex, marital status, age, or if an applicant's income stems from public assistance.
On the other hand, the FHA (enforced by the U.S. Department of Housing and Urban Development) prohibits discrimination in housing-related transactions, including the sale, rental, and financing of dwellings based on race, color, religion, sex, disability, familial status, or national origin.1
Both regulations work together to promote fairness and equality in financial and housing markets, helping safeguard that individuals are not discriminated against while obtaining credit or housing loans.
The CRA & HMDA
The CRA can be viewed as the cousin regulation to ECOA and FHA. Together, these regulations work to create a more equitable financial and housing environment by making sure that individuals and communities have fair access to credit and housing opportunities.2
The CRA focuses on income by encouraging banks to meet the credit needs of all community members, including low- and moderate-income neighborhoods, which helps to provide fair access to credit. Race, income, and geography are often highly correlated in many still-residentially-segregated cities in the United States.3 Low-and moderate-income areas may also contain significant minority populations.
Finally, the HMDA is invited to the reunion as this regulation is the matriarch and historian of the family. HMDA focuses on data and data collection, helping to identify discriminatory lending patterns by requiring lenders to report detailed information on mortgage applications. This transparency helps to confirm that lenders equitably serve the housing needs of their communities.4
One Big, Happy Family
All four regulations provide a solid foundation for a fair lending program and act as members of a family, each with their unique roles and responsibilities working together to maintain harmony and fairness. Family dynamics can create challenges, and the fair lending family reunion is no different. Communication obstacles, hidden biases, and inaccurate data can impact balance and harmony among regulatory compliance programs.
If you are interested in learning more about “our family” while maintaining a proactive fair lending program, be sure to save the date for the Fair Lending Family Reunion seminar in St. Louis, Missouri from July 15 to 16 and in Louisville, Kentucky from September 23 to 24. Kylee Durbin and Ginger McCullough will share their experiences building and managing fair lending programs.
In addition, the 2025 Spring Regulatory Compliance Conference in Lexington, Kentucky from May 12 to 16 offers more learning opportunities on this subject matter. Our team will discuss trending insights on deposits, lending, AML/BSA, and relevant compliance risk management topics. Event details and registration can be found here.
For more information on fair lending programs, please reach out to a professional at Forvis Mazars.
- 1 “Fair Housing Act (as amended) – Title VIII of the 1968 Civil Rights Act,” hud.gov, 2025.
- 2“Community Reinvestment Act – CRA Main,” ffiec.gov, 2025.
- 3“Fair Lending Laws and the CRA: Complementary Tools for Increasing Equitable Access to Credit,” minneapolisfed.org, March 8, 2018.
- 4“Home Mortgage Disclosure Reporting Requirements (HMDA),” consumerfinance.gov, 2025.