Mystery Shoppers Presented by Tammy Butler Master CMB What you dont know can kill YouDave Ramsey Manager instructed loan officers and processors under her supervision that mortgage applications from minorities and others viewed as protected class must be turned down in 21 da ID: 652150
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Slide1
Positioning Your Business For Success
Mystery Shoppers
Presented by: Tammy Butler, Master CMBSlide2
“What you don’t know can kill You-Dave Ramsey”Slide3
•Manager instructed loan officers and processors under her supervision that mortgage applications from minorities and others viewed as "protected class" must be " turned down" in 21 days and that "borderline" customers should be turned down quickly, while applications from White applicants were not subject to this shorter review period.
•When asked for an explanation for the explicitly race-based denial policy, the manager stated, "I think it's lawsuits, it's lawsuits, and we just dodged a really large bullet."
•A loan officer asked the manager whether loan officers should help marginally qualified applicants improve their credit scores so their applications would be approved. The manager cautioned against doing so stating that "you are
gonna spend two weeks trying to get it re-scored and get that credit score up and by that time they're mad and sending you mean letters." ●A loan officer commented that "they need to get their credit up" and "stop paying their damn bills late" and then laughed. ●In discussing the Bank's hiring of an African-American employee, a loan processor cautioned, "don't use then “n” word." A few moments later, a Bank employee quipped "what's up, niggas!" Both of these comments were followed by laughter in the room.
Recorded Examples-Source CFPB/DOJSlide4
The Basics
Who Are They?
• Regulators
• Consumer Advocacy Groups• Your Competition• Industry Analysts• Your CompanyHow Is it Done?•Over the Phone•In Person•Through Social Media
Interaction
●
Texting
How is Info Used?
•
Regulatory Compliance
• Basis for Complaints to HUD
or the CFPB
• Market Knowledge/Intel
• Market Condition AnalysisSlide5
Who Is Chosen & Why?Slide6
Science Behind the Shopping
Testing for Disparate Treatment
Financial Profiles are Similar
Minority Shopper is Given a Slightly Better ProfileLO is Contacted the Same WayExact Communication Techniques re: Follow upWill Ask Similar Types of QuestionsEach interaction and Answer is Carefully Documented, Directly After the Meeting.Slide7
What Testers are
Unlikely
to do
Negotiate for a better rate/cost.Give you “deep information” like a social security number, or birthdate.Authorize a credit pull.Pay for any services.State any preference for loan optionsIndicate that they are working with a real estate agentSlide8
Ways to Protect you & Your Team
Training, Training, Training!
Test Your Branch Employees
If You Run a Team, Test Your “Firewall” Employees-Improper ScreeningBe Present & Keep Your Ears OpenAutomate Proper Follow-Up Controls-i.e. Mortgage CoachTrack Fall Out Clients/Leads Why did they not apply?Where did the go?Did Employees Follow up? Slide9
Tammy Butler, Master CMB, LSS Black Belt
tammybutler@fairlendingdiversity.com
www.fairlendingdiversity.com
847-276-0399
Contact Us for:
●
Mystery Shopping Training
•Fair Lending Training-Staff & Board
•Pricing Policy & Procedures Creation & Review
•Pricing Engine Configuration Review
•Fair Lending Policy
•CMS Development for Fair Lending
•Redlining Evaluation & Remediation
•Community Needs Analysis & Peer Analysis
•Disparate Impact Reviews
Thank You!