Nondiscriminatory Mortgage Origination Policies and Procedures

Banner Bank has comprehensive written fair lending policies and procedures that include: 

•  Loan Policy

• Complaince Management System Policy

• Complaint Management Policy

• Fair Lending Policy

• Unfair, Deceptive or Abusive Acts and Practices (UDAAP) Policy

• Home Mortgage Disclosure Act Procedures

• Fair Lending General Procedure Guide

• Mortgage Banking Operational Guidelines that include procedures addressing compliance with the Equal Credit Opportunity Act (ECOA) and the Fair Housing Act as implemented by the Department of Housing and Urban Development (HUD), as well as RESPA and Regulation Z

• Guidance documents from FNMA, FHLMC, USDA, VA and FHA

These policies and procedures are applied in sales practices, underwriting practices, terms and conditions of loan products, marketing, pricing, and servicing. The Mortgage department staff are required to comply with lending policies and guidance documents in every step of the life cycle of a mortgage loan. We also have a CRA and Fair Lending Committee that meets regularly to discuss and document trends related to HMDA data, loans originated to low-to-moderate income (LMI) borrowers and in LMI census tracts and reports on redlining risks.