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An MLO working for a bank that originated 200 covered loans last year notices unusual patterns in denial rates by race in their portfolio. What is the MLO's primary obligation regarding this observation?

Correct Answer

B) Document the observation and report it through internal compliance channels

MLOs should report potential fair lending concerns through their institution's internal compliance procedures. The institution's compliance department is responsible for conducting proper analysis and determining appropriate action, including potential regulatory reporting.

Answer Options
A
Immediately report the pattern to the CFPB
B
Document the observation and report it through internal compliance channels
C
Conduct their own statistical analysis to confirm discrimination
D
Change their underwriting practices to equalize approval rates

Why This Is the Correct Answer

MLOs should report potential fair lending concerns through their institution's internal compliance procedures. The institution's compliance department is responsible for conducting proper analysis and determining appropriate action, including potential regulatory reporting.

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