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| Chase's goal is to promote equal access to all credit products and services. Chase has an extensive fair lending program designed to ensure that every applicant receives fair and equal treatment. Our commitment to fair lending is reflected in our fair lending policy statement, our fair lending program, our outreach initiatives and our community programs. We are always seeking to do more. |
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Chase's Fair Lending Policy Statement. Our fair lending program begins with our Fair Lending Policy Statement, approved by Chase's Board of Directors in 2007:
JPMorgan Chase& Co. (JPMorgan Chase) is committed to treating all individuals fairly and equitably in the conduct of its lending businesses in all jurisdictions where it conducts business. This commitment is part of our fundamental mission of providing quality financial services to existing and prospective customers in accordance with all applicable laws. In the United States, this principle is embodied in fair lending laws such as the Equal Credit Opportunity Act and the Fair Housing Act. These laws require the equitable treatment of all credit applicants, without regard to race, sex, sexual orientation, color, national origin, religion, age, marital status, disability or other prohibited basis. Denying any person equal access to basic economic opportunities, such as home ownership or credit, is morally repugnant, and has no place in our company and will not be tolerated.
Only through the efforts of all of us at JPMorgan Chase can we ensure that every applicant for credit receives fair and equitable treatment and that we have helped each member of the communities JPMorgan Chase serves reach his or her fullest potential.
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Employee Training. Chase educates its employees about fair lending in several ways:
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Training new employees on fair lending laws and regulations; |
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Training underwriters and other customer-facing personnel, and business partners, periodically on fair lending laws and regulations; |
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Distributing biannually a fair lending brochure to every employee in Chase Home Lending that contains extensive background on fair lending rules and government regulatory agencies. The brochure can be found here. |
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Monitoring the Loan Approval Process. Chase takes many steps to ensure applicants are treated fairly in the loan approval process, including:
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Reviewing annually all credit policies for disparate impact on protected groups; |
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Reviewing all declined first mortgage applications by a more senior underwriter; |
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Reviewing declined minority and low- and moderate-income tract and borrower applications by underwriters with access to a special purpose credit program; |
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Reviewing targeted files of approved and declined applications by an independent team of fair lending underwriters to ensure consistency in the credit decision; if an application was inappropriately declined, an offer of credit is made. |
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Fair Pricing Initiatives. Chase also has a number of initiatives to ensure that loans are priced fairly, including:
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Testing loans to ensure that fees and pricing do not exceed HOEPA thresholds; |
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Imposing caps on fees and loan prices, and providing refunds to customers where the caps are exceeded; |
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Monitoring loan pricing by loan officers, branches and brokers for discretionary pricing on protected classes, and providing counseling and other sanctions when needed; |
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Creating a "referral-up" process for retail applicants entering the subprime channel who appear to qualify for prime pricing; the applicant is given the option to have the application transferred to the prime channel. |
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| Company Oversight of Fair Lending. Within Chase, each production channel has regular fair lending meetings with senior executives with oversight responsibilities, including Chase's Corporate Fair Lending Officer. In addition, Home Lending has its own weekly fair lending team meeting to discuss the status and cause of any fair lending complaints, progress against the fair lending plan, fair lending training efforts, and data trends and analysis. |
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