AI Playbook for Fair Lending Examination Preparation

A bank has received a 90-day notice of a joint OCC/CFPB fair lending examination. The bank has a mortgage portfolio, auto loan portfolio, and small business lending program. Prior examinations noted concerns about pricing discretion. The compliance team has 90 days to prepare.

When to use this playbook

• Use this playbook when the decision looks like the situation above: A bank has received a 90-day notice of a joint OCC/CFPB fair lending examination.
• It is a fit when you have source files in hand and need a structured, reviewable analysis — not a generic chat answer about "Fair Lending Examination Preparation".
• Do not use it as a substitute for licensed, legal, clinical, or authorized official judgment in the domain.

What you'll need

• Prior examination reports (2 most recent cycles)
• Current mortgage, auto, and small business loan data (HMDA LAR and equivalent)
• Compliance management system documentation
• Fair lending training records
• Examination notification letter and stated scope

Attachments: Multiple attachments (Spreadsheets, Documents)

You are a compliance officer developing a fair lending examination preparation plan for a joint OCC/CFPB examination. I am attaching:

Work only from the attached source files. If a conclusion is not supported, say so.

Produce:
1. Identify the top 5 areas the examiners are most likely to focus on based on prior findings and current portfolio data—map the risk to specific examiner test procedures.
2. Conduct a self-test of each portfolio: run the same analysis the examiners will run on pricing, approval rates, and geographic distribution.
3. Identify any findings that the self-test reveals that should be remediated before the examination starts—early remediation is mitigating.
4. Prepare the document request response: what records the examiners will ask for on Day 1 and how to organize the production.
5. Tell me the examination management strategy: who speaks for the bank, what we provide proactively, and what we do not provide without a specific request.

Call out where independent models are likely to disagree, and list follow-up documents a reviewer should request.

What to expect

• Top 5 examination focus area predictions
• Self-test results by portfolio
• Pre-examination remediation priority list
• Day 1 document production organization
• Examination management strategy

Review before you act

• Validate this output against source files before relying on it: Identify the top 5 areas the examiners are most likely to focus on based on prior findings and current portfolio data—map the risk to specific examiner test procedures.
• Validate this output against source files before relying on it: Conduct a self-test of each portfolio: run the same analysis the examiners will run on pricing, approval rates, and geographic distribution.
• Validate this output against source files before relying on it: Identify any findings that the self-test reveals that should be remediated before the examination starts—early remediation is mitigating.
• Validate this output against source files before relying on it: Prepare the document request response: what records the examiners will ask for on Day 1 and how to organize the production.
• Confirm every cited figure, date, counterparty, or requirement against the attached originals — models compress and can drop a qualifier.
• Treat disagreement between models as a review item, especially on classification, materiality, and recommended next action.
• Do not authorize an operational, clinical, legal, credit, or enforcement action solely because the models agree.