We perform a Fair Lending Assessment to identify any potential discrimination or prohibited bias in lending activities. The scope of the assessment encompasses the loan product(s), market(s), decision center(s), marketing efforts, lending trends and peer data in formulating appropriate prohibited basis and control group) that will be the basis of the focal points of the assessment. When determined appropriate, we perform comparative file testing where a statistical sample can be developed in accordance with interagency examination guidelines to do so, evaluating results for any disparate treatment in approval decisions, as well as terms granted and pricing. We also evaluate the institution’s management of fair lending risk through review of internally developed risk assessments, policies and procedures, internal monitoring of policy exceptions and pricing overrides, training, and management and board reporting.