Fair
Lending
7070 S. Union Park Ave. Suite 260
Midvale, UT 84047
P. 888.409.1560
info@visibleequity.com
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Fair Lending Agenda
Fair Lending The Basics
Fair Lending Performance Reports
Assessing Your Fair Lending Risk
Statistical Modeling
and Comparative File Reviews
Building a Fair Lending Program
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Fair Lending the Basics
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Fair Lending the Basics
www.visibleequity.com
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Fair Lending the Basics
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Fair Lending the Basics
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Fair Lending the Basics
Fair Lending Laws and Prohibited Basis Groups
FH Act
-Handicap
-Familial Status
Fair Housing Act (FH Act)
BOTH
ECOA
-Race or color
-Religion
-National Origin
-Sex
-Marital Status
-Age
-Source of Income
Equal Credit Opportunity Act (ECOA)
Prohibits discrimination in residential real estate transactions: Prohibits discrimination in any aspect of a
-making loans to buy, build, repair, improve a dwelling
consumer credit transaction (including small
-purchasing real estate loans
businesses).
-selling, brokering, or appraising residential real estate
-selling or renting a dwelling
+ Reg B, HMDA, and CRA are related
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Fair Lending the Basics
Fair Lending and The Lending Cycle
PreApplication
-Modifications
-Default Remedies
-REO
-Approval Criteria
-Final Terms & Conditions
-Appraisal Practices
Servicing /
Post-closing
-Advertising & Market Selection
-Channels
-Responding to Inquiries
Application
Underwriting /
-Level of Assistance
-Use of 3rd Parties
-Initial Terms & Conditions
Closing
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Fair Lending the Basics
Prohibited Practices
A lender may not because of a prohibited basis:
1. Fail to provide or provide different information or services regarding any aspect of the lending process
2. Discourage or selectively encourage individuals who inquire or apply for credit
3. Refuse to extend credit or use different standards in determining whether to extend credit
4. Vary the terms of credit offered
5. Use different standards to evaluate collateral
6. Treat a borrower differently in servicing a loan or making invoking default remedies
7. Use different standards for pooling or packaging loans in the secondary market
A lender may not discriminate on a prohibited basis by considering the characteristics of:
1. An applicant, prospective applicant, or borrower
2. A person associated with an applicant, prospective applicant, or borrower
3. The present or prospective residents of the property to be financed
4. the neighborhood where the property to be financed is located
Pre-Application
Servicing / Postclosing
Application
Underwriting /
Closing
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Fair Lending the Basics
Types of Discrimination
1. Disparate Treatment
Treating an applicant or borrower differently due to a prohibited basis during any aspect of the lending
process.
>Overt Discrimination
-Lender openly discriminates on a prohibited basis (can be written or verbal)
>Comparative Evidence
-Differences in treatment not fully explained by legitimate non-discriminatory factors
*Does not require evidence the lender intended to discriminate or was motivated by prejudice
2. Disparate Impact (“Effects Test”)
When an otherwise neutral policy or practice has a disproportionately negative impact on
persons from a prohibited basis group.
*A disparate impact claim must show the challenged policy or practice is either not justified
by a valid business propose or that the business justification could be accomplished using a
less discriminatory alternative.
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Fair Lending the Basics
Discrimination?
Example 1
Example 2
-For joint applicants, combine the debts and
income of married joint applicants to calculate
debt-to-income ratio and for unmarried joint
applicants calculate an individual debt-toincome ratio for each applicant.
Credit Card Limits:
-$750 for age 21-30
-$1,500 for age over 30
Yes!
Yes!
Prohibited Basis: Marital Status
Prohibited Basis: Age
Discrimination Type: Disparate Treatment-Overt
Discrimination Type: Disparate Treatment-Overt
Prohibited Practice:
Refuse to extend credit or use different standards
in determining whether to extend credit
Prohibited Practice:
Vary the terms of credit offered
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Fair Lending the Basics
www.visibleequity.com
Discrimination?
Example 4
Example 3
Borrower
National Origin
Number of
Home Purchase
Loans
Average
Interest
Rate
Hispanic
125
12.5%
Non Hispanic
White
150
8.5%
The financial institution has a policy not to
make loans less than $150,000.
The average home value in the area is less than
$150,000 resulting in no loans being made in
certain areas.
Discrimination?
Potentially
Discrimination?
Potentially
Prohibited Basis:
National Origin
Prohibited Basis:
Race, Familial or Marital Status
Discrimination Type:
Disparate Treatment-Comparative Evidence
Discrimination Type:
Disparate Impact
Prohibited Practice:
Vary the terms of credit offered (Pricing)
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Fair Lending the Basics
U.S. Department of Housing and Urban Development
Office of Policy Development and Research
All Other Things Being Equal:
A Paired Testing Study of
Mortgage Lending Institutions
Final Report
April 2002
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Fair Lending the Basics
All Other Things Being Equal:
A Paired Testing Study of
Mortgage Lending Institutions
In a paired test, two individuals―one white and one minority―pose as
homebuyers and inquire about the availability and terms for home
mortgage loans. Because the two members of a tester team present
themselves as equally qualified borrowers in every respect except their
race or ethnicity, systematic differences in the treatment they receive
provide direct evidence of adverse treatment discrimination.
The Results?
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Fair Lending the Basics
The Results
In Los Angeles Blacks were offered less coaching than comparable white homebuyers and were
more likely to be encouraged to consider an FHA loan.
Hispanics were denied basic information about loan amount and house price, told
about fewer products, and received less follow-up than comparable Anglo
homebuyers.
In Chicago –
Blacks were denied basic information about loan amount and house price, told about
fewer products, offered less coaching, and received less follow-up than comparable
white homebuyers.
Hispanics were quoted lower loan amounts or house prices, told about fewer
products, and offered less coaching than comparable Anglo homebuyers.
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Fair Lending the Basics
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Fair Lending the Basics
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Fair Lending the Basics
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Fair Lending the Basics-
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Fair Lending the Basics
Bank of America Settlement ($335 M)Accused of Discriminatory Lending (at Countrywide Home Loans)
Discrimination Type:
Disparate Treatment-Comparative Evidence (Statistical Analysis & Interviews)
Prohibited Practices:
Steering Claims (vary the terms of credit, others)
Pricing Claims (vary the terms of credit)
Findings:
African Americans 3x more likely to be put in a “subprime” product than similarly
situated white borrowers
Sources of Fair Lending Risk:
Policies and procedures inadequate
Loan officers were given discretion in setting rates, fees, and terms
Loan officers were compensated for putting buyers in higher priced loans
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Fair Lending Assessing Your Risk
The 5* Main Sources of Potential Fair Lending Risk
1.
Marketing Activities
2.
Discretion Permitted
3.
Exceptions
4.
Role of Third Parties
5.
Incentives & Compensation
*In addition to overt discrimination and the technical requirements of Reg B and other fair lending
laws.
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Marketing Activities
How and where you offer credit products are not just fundamental business decisions, they have
fair lending implications as well.
Redlining
The illegal practice of refusing to make loans or imposing more onerous terms on borrowers
because of the racial, national origin, or other prohibited basis characteristics of the residents of a
subject neighborhood.
Reverse Redlining
Reverse redlining is the deliberate targeting of residents of such neighborhoods with less
advantageous or potentially predatory products.
Steering
The guiding of an applicant or a borrower to a less advantageous product on a prohibited basis
rather than on the legitimate needs.
Advertising
Advertising methods that could discourage individuals from apply for loans or in media that exclude
specific regions are sources of fair lending risk
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Marketing Activities
On a scale of 1-5 rate your institution on the level of potential fair lending risk (this does not mean
violations are occurring only that the potential exists)
Market Demographics
Does your institution operate in a competitive and diverse market or a market with little completion
and diversity? Do the areas in which you operate exclude any areas that might be considered
majority minority or lower income?
1
Stable Market/All Areas
Low Competition
Low Diversity
2
3
4
5
Evolving Market/Sporadic Areas
High Competition
High Diversity
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Marketing Activities
On a scale of 1-5 rate your institution on the level of potential fair lending risk (this does not mean
violations are occurring only that the potential exists)
Delivery Channels
Does your institution have multiple delivery channels (e.g. website, telephone, face-to-face, third
parties, etc.)? Do decisions and processes related to application processing, underwriting, pricing,
servicing, etc. vary by channel? Do you have “subprime” or similar subsidiaries or related businesses
you refer certain applicants to?
1
2
Limited Channels
Decisions/Processes do not vary by channel
No Subprime Subsidiaries/Partners
3
4
5
Multiple Channels
Decisions/Processes vary by channel
No Subprime Subsidiaries/Partners
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Marketing Activities
On a scale of 1-5 rate your institution on the level of potential fair lending risk (this does not mean
violations are occurring only that the potential exists)
Product Complexity
Do you offer “non-traditional”, “subprime” or other products the industry would consider complex,
difficult to understand, or potentially less advantageous than traditional products?
1
2
3
4
Traditional Product Mix
5
Complex and Non-traditional Product Mix
New Products Reviewed for Fair Lending Compliance
New Products Not Reviewed
Advertising
How complex is your advertising program? Do you advertise in multiple media platforms and/or in
multiple languages? Is your advertising constantly changing? Do you advertise exclusively in areas or
through media that is targeted at areas considered majority minority or lower income? Could any of
your advertising pieces be considered threatening or discouraging to a protected class?
1
2
3
4
5
Limited Advertising
Extensive Advertising
No Recent Changes
Constantly Changing Advertising
Broad Based
Targeted
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Marketing Activities
How did you score?
Source
Marketing Activities
-Market Demographics (1-5)
-Delivery Channels (1-5)
-Product Complexity (1-5)
-Advertising (1-5)
Score
Low
<=6
Medium
7-9
10-12
High
13-15
>=16
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Discretion Permitted
Allowing discretion has many benefits and in fact is usually used in the favor of the
applicant or borrower.
However, the level of individual discretion permitted in certain activities such as approvals
or pricing increases an institution’s fair lending risk. Centralized lending operations with
clear and objective non discriminatory policies and procedures that are taught, followed,
and monitored significantly reduces the level of fair lending risk.
On a scale of 1-5 rate your institution on the level of potential fair lending risk (this does not mean
violations are occurring only that the potential exists)
Discretion Permitted
How much discretion is permitted? Does the degree of permitted discretion vary by geography,
channel, or activity? Can the exercise of discretion impact compensation? Do disparities by a
prohibited basis group exist in the discretion exercised?
1
2
Limited and Consistent Discretion
Discretion criteria is clear
Discretion does not impact compensation
No Disparities Resulting From Exercised Discretion
3
4
5
Broad and Variable Discretion
Discretion criteria is broad or non-existent
Discretion does impact compensation
Unexplained Discrepancies Exists
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending-Discretion Permitted
How did you score?
Source
Score
Low
Medium
High
Marketing Activities
<=6
7-9
10-12
13-15
>=16
Discretion Permitted
1
2
3
4
5
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Exception Handling
In many cases granting an exception is the right decision. However, exceptions should be made
consistently for similar reasons for similarly situated applicants or borrowers. Exceptions should be
documented and monitored to ensure they are being used properly.
On a scale of 1-5 rate your institution on the level of potential fair lending risk (this does not mean
violations are occurring only that the potential exists)
Exception Handling
Is file documentation accurate and descriptive? Is rationale objective? Are exceptions low in
number? Do exceptions vary by prohibited basis group? Do certain loan officers, branches, etc. have
a higher level of granting exceptions?
1
2
Exceptions are Objective and Well Documented
Exceptions are Few
No Disparities by Prohibited Basis Group
3
4
5
Exceptions are Subjective and Not Well Documented
Exceptions are Many
Disparities by Prohibited Basis Group
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Exception Handling
How did you score?
Source
Score
Low
Medium
High
Marketing Activities
<=6
7-9
10-12
13-15
>=16
Discretion Permitted
1
2
3
4
5
Exception Handling
1
2
3
4
5
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Role of Third Parties
Third party operators (TPOs) such as mortgage brokers and auto dealers offer legitimate
opportunities to extend lending operations and enhance product offerings.
From a fair lending perspective TPOs are the financial institution and if any TPO does not comply
with fair lending regulations the financial institution may be as culpable as if you were the initial
creditor.
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Role of Third Parties
Consumer
1. Consumer submits application
to Dealer
Lender
Dealer
6. Dealer sales the contract
to the chosen Lender
2. Dealer submits application
to Lender(s)
Lender(s)
Dealer
5. Consumer and Dealer
close the sale
Consumer
Q: Where is the Fair Lending Risk
in this process?
Dealer
Lender(s)
Lender(s)
3. Lender(s) submit “buy rate”
and dealer compensation to
dealer
4. Dealer sets actual rate to consumer
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Role of Third Parties
On a scale of 1-5 rate your institution on the level of potential fair lending risk (this does not mean
violations are occurring only that the potential exists)
The Role of Third Parties
Do you use TPOs? Is due diligence performed? Do you have written agreements addressing fair
lending obligations? Do agreements define who is responsible and accountable? Do you receive
regular reporting? Does the TPO have frequent complaints? Does the TPO conduct fair lending
training?
1
2
Little or No Use of Third Parties
Due Diligence Performed
Written Agreements w/ Accountability Defined
Receive Regular Reporting
3
4
5
Extensive Use of Third Parties
No Due Diligence Performed
No Written Agreements w/ Accountability Not Defined
Receive No Reporting
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Role of 3rd Parties (TPOs)
How did you score?
Source
Score
Low
Medium
High
Marketing Activities
<=6
7-9
10-12
13-15
>=16
Discretion Permitted
1
2
3
4
5
Exception Handling
1
2
3
4
5
Role of Third Parties
1
2
3
4
5
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending-Incentives & Compensation
Compensation tied to loan production can be a great motivator for a tough job, but it can also lead
to significant fair lending issues. If loan officers or other decision makers are incented to steer
borrowers into certain products disparate impact against protected groups can occur.
On a scale of 1-5 rate your institution on the level of potential fair lending risk (this does not mean
violations are occurring only that the potential exists)
Incentives & Compensation
Are your loan officer and other decision makers compensated on loan production? Is compensation
tied to higher pricing or higher fees?
1
2
Incentives & Compensation Not Tied to Loan
Production
Incentives & Compensation Not Tied to Loan Pricing
and/or Fees
3
4
5
Incentives & Compensation Tied to Loan Production
Incentives & Compensation Tied to Loan Pricing and/or
Fees
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Fair Lending Assessing Your Risk
The 5 Main Sources of Fair Lending Risk-Incentives & Compensation
How did you score?
Source
Low
Medium-Low
Medium
Medium-High
High
Marketing Activities
<=6
7-9
10-12
13-15
>=16
Discretion Permitted
1
2
3
4
5
Exception Handling
1
2
3
4
5
Role of Third Parties
1
2
3
4
5
Incentives & Compensation
1
2
3
4
5
<=12
13-19
20-26
27-33
>=34
TOTAL
Score
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Fair Lending Assessing Your Risk
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Fair Lending Assessing Your Risk
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Fair Lending Performance Reports
Key Fair Lending Performance Reports
Applications
-Acceptance/Denial Rates
-Expected Acceptance Rates
-Application Disposition
BOTH
-Marketing/Redlining
-Steering
-Pricing
-Exceptions
-Decisionmaker Analysis
Portfolio
-Modifications/Defaults
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Fair Lending Performance Reports
Key Fair Lending Performance Reports-Application Rates
Approved
Applications
Denied
Applications
Total Applications
Approval /Denial
Rates
Denial Relative
Impact
White
1000
100
1100
90.9%/9.1%
1.0
Hispanic
500
200
700
71.4%/28.6%
3.14
Black
150
150
300
50%/50%
5.5
Etc.
-Application Rates by Race/Ethnicity, Gender, Age, Marital Status, Census Tract Metric (Income,
Majority Minority, Etc.
-Higher denial rates indicate potential disparate treatment.
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Fair Lending Performance Reports
Key Fair Lending Performance Reports-Expected Approval Rates
Actual Approval
Rate
Expected
Approval Rate
Status
White
92.3%
90.0%
OK
Hispanic
55.0%
58.2%
OK
Black
22.3%
43.4%
!
Etc.
-Approval Rates by Race/Ethnicity, Gender, Age, Marital Status, Census Tract Metric (Income,
Majority Minority, Etc.
-The Expected Approval Rate incorporates borrower and collateral risk. Differences are an indication
of disparate treatment.
-The difference between actual and expected must be significant in terms of both statistical
accuracy and magnitude.
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Fair Lending Performance Reports
Key Fair Lending Performance Reports-Application Disposition
Total Applications
Approved
Applications
Denied
Applications
Withdrawn
Applications
White
1200
1000 (83.3%)
100 (8.3%)
25 (2.0%)
Hispanic
800
500 (62.5%)
200 (25.0%)
50 (6.2%)
Black
400
150 (37.5%)
150 (37.5%)
60 (15.0%)
Etc.
Etc.
-Application Disposition by Race/Ethnicity, Gender, Age, Marital Status, Census Tract Metric
(Income, Majority Minority, Etc.), Etc.
-High Levels of withdrawn applications are an indicator of potential disparate treatment.
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Fair Lending Performance Reports
Key Fair Lending Performance Reports-Marketing/Redlining
% of Loan Count
% of Market Area
Market Relative
Impact
Upper Income
12.5%
10%
.8
Middle Income
70%
60%
.86
12.5%
5%
.4
5%
25%
5.0
Moderate Income
Low Income
-Applications or Loans by Race/Ethnicity, Gender, Age, Marital Status, Census Tract Metrics (Income,
Majority Minority, Etc.), Etc.
-Disparities between application or portfolio mix and market area mix are an indication of potential
redlining.
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Fair Lending Performance Reports
Key Fair Lending Performance Reports-Steering
% White
% Hispanic
% Black
Product A
70%
10%
10%
Product B
75%
8%
8%
Product C
7%
85%
80%
Etc.
Etc.
-Applications or Loans by Race/Ethnicity, Gender, Age, Marital Status, Census Tract Metrics (Income,
Majority Minority, Etc.), Etc.
-Higher levels of Prohibited Basis Groups in certain products are an indication of potential steering.
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Fair Lending Performance Reports
Key Fair Lending Performance Reports-Pricing
Avg. Rate
Expected Rate
Risk Indicator
White
5.0%
5.2%
OK
Hispanic
7.5%
5.7%
!
Black
9.2%
9.5%
OK
Etc.
Etc.
-Rates by Race/Ethnicity, Gender, Age, Marital Status, Census Tract Metric (Income, Majority
Minority, Etc.
-The Expected Rate incorporates borrower and collateral risk. Differences are an indication of
disparate treatment.
-The difference between actual and expected must be significant in terms of both statistical
accuracy and magnitude.
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Fair Lending Performance Reports
Key Fair Lending Performance Reports-Exceptions
% White
% Hispanic
% Black
Exception Code 1
75.0%
5.2%
4.2%
Exception Code 2
72.5%
5.7%
3.5%
Exception Code 3
90.2%
1.5%
2.5%
Etc.
Etc.
-Exceptions by Race/Ethnicity, Gender, Age, Marital Status, Census Tract Metric (Income, Majority
Minority, Etc.
-Differences between control group (White) and prohibited basis groups are an indication of
disparate treatment.
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Fair Lending Performance Reports
Key Fair Lending Performance Reports-Decision Maker Analysis
Avg. Rate
Expected Rate
Risk Indicator
Loan Officer A
5.0%
5.2%
OK
Loan Officer B
7.5%
5.7%
!
Loan Officer C
9.2%
9.5%
OK
Etc.
Etc.
-Rates by Loan Officer, Underwriter, Dealer, Branch Etc.
-The Expected Rate incorporates borrower and collateral risk. Differences are an indication of
disparate treatment.
-The difference between actual and expected must be significant in terms of both statistical
accuracy and magnitude.
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Fair Lending Performance Reports
Key Fair Lending Performance Reports-Modifications/Defaults
Modifications
Granted
Modifications
Denied
% White
% Hispanic
% Black
75.0%
5.2%
4.2%
2.5%
85.7%
93.5%
Etc.
-Modification Rates by Race/Ethnicity, Gender, Age, Marital Status, Census Tract Metric (Income,
Majority Minority, Etc.
-Differences between % of control group (White) and % of prohibited basis groups are an indication
of potential disparate treatment.
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Fair Lending Statistical Analysis
Calculating Expected Race/Ethnicity
Step 1. Match Borrower to Census Tract
Step 2. Calculate Baseline Expected Race Using Census
Step 3. Match Borrower Surname to Name/Race Database
Step 4. Apply Bayesian Statistics to Update Baseline Expected Race
P(Ethnicity|Given Surname) =
P(Given Surname|Ethnicity)*P(Ethnicity)
P(Given Surname|Ethnicity)*P(Ethnicity) + P(Given Surname|Not Ethnicity)*P(Not Ethnicity)
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Fair Lending Statistical Analysis
Calculating Expected Rate
Use multivariate regression analysis with variables such as:
-Credit Score
-Loan-to-Value
-Debt-to-Income
-Baseline Rate
-Etc.
This analysis allows for more than one metric to be compared at the same time!
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Fair Lending Statistical Analysis
Comparative File Review
The goal of a comparative file review is to ensure all applicants received a comparable level of
assistance, the credit decision for similarly situated borrowers was the same, the terms and
conditions were substantially the same, and whether any remedial action is necessary.
Approve/Deny Decisions
Use Only Marginal Transactions
Applicants that are neither clearly qualified nor clearly unqualified.
Determine Benchmark Applicant
The applicant with the least deficient reason for denial. In other words the most
qualified of the denied applications for a given metric.
Compare marginal approvals with Benchmark.
If there are no approvals less qualified for a given metric then no disparate
treatment exists. If there are approvals less qualified than the bench mark then
potential disparate treatment exists.
Overlap Approval
An approved applicant that is no better qualified than the benchmark applicant.
Note all overlap approvals and research further.
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Fair Lending Statistical Analysis
Comparative File Review
The goal of a comparative file review is to ensure all applicants received a comparable level of
assistance, the credit decision for similarly situated borrowers was the same, the terms and
conditions were substantially the same, and whether any remedial action is necessary.
Pricing Decisions
Compare each more favorably treated control group with similarly situated
prohibited basis group who received less favorable treatment.
Follow up with and resolve any disparate treatment found.
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Fair Lending Program
Any weaknesses or violations are
promptly corrected , including
appropriate restitution.
Tone at The
Top
Correction
Fair Lending is cultural and
reinforced at the highest levels
and throughout the organization
in both written and verbal forms.
Policies &
Procedures
P&Ps provide clear guidance and
are free of overt discrimination.
Fair lending compliance and
performance is regularly
reported and monitored
Performance
Monitoring
Training
Training occurs regularly, is well documented,
attendees are tested, and trainings include role
specific instructions. Trainees include top
management, board members, and new employees.
Assessing Fair
Lending Risk
Assess and correct or mitigate, as
appropriate, heighted fair lending
risk areas.
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Fair Lending Program
Financial Institutions make loans to any and all qualified borrowers using sound
underwriting and pricing decisions applied consistency and equally to similarly situated
borrowers without regard to any prohibited basis, such as race, gender, or age.
“Fair Lending, then, is the natural state of bank (credit union) credit operations.”
ABA Toolbox
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Sources
-Visible Equity
-Comptroller’s Handbook, Fair lending, January 2010
-ABA Toolbox on Fair Lending
-Indirect Auto lending-Fair Lending Considerations, Webinar, August 6, 2013
-FDIC Presentation on Fair Lending
-NCUA, Office of Consumer Protection, Fair Lending Guide, March 2013
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on addressing potential problems rather than spending
endless hours running reports and analyzing data. We
continue to be impressed with the service we receive and
with the functionality, accuracy, and delivery of the
product. Visible Equity has been a great partner to work
with for our credit union.”
Jeff Meyers
Utah Community Credit Union
Address:
7070 S. Union Park Ave., Suite 260
Midvale, UT 84047
Phone:
+1 888 409 1560
Email:
info@visibleequity.com
https://www.linkedin.com/company/visible-equity
facebook.com/visibleequity
twitter.com/visibleequity
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