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How LendingPatterns™ helps you make sense of HMDA
HMDA data is both a recurring concern and a useful tool for financial institutions. Banks, credit unions, and independent mortgage companies have to submit HMDA every year or risk the penalties so that all of this data can then be viewable to the public and can paint...
Maintaining Your HMDA Data Accuracy to Avoid Penalties
When it comes to your client’s data, your main priority should rightly be keeping it secure from any third parties. However, when the time comes to deliver the data and you have accidentally omitted a piece of information, it can have serious consequences for you...
Five Reasons for Doing a HMDA Scrub
With only a few months left before your March 1 filing, now is a good time to plan the year-end HMDA scrub. The point of a HMDA Scrub is to compare specific data in the loan application register (LAR) to loan origination source...
Analyzing “Not Provided” Race/Ethnicity in HMDA Data Before Submission
An old adage is that statistical analysis can only be as good as the data that goes into it. Garbage in, garbage out. In the realm of fair lending analysis, there is a dilemma that every analyst must deal with, namely, how to handle and analyze HMDA records where race...
5 Ways HMDA Data Are Used in Fair Lending Analysis: Your analysis is only as good as the data
Fair lending analysis attempts to use lending transaction data to tell the story of the evenhandedness of underwriting, pricing, and marketing decisions in terms of what happened when, where, why, how, and to whom. Fair lending compliance managers may use HMDA...
5 Ways to Use HMDA Data in a Non-Fair Lending Context
I have always been shocked by the reluctance of lenders to use HMDA data for reasons other than fair lending. Too often, mentioning the four letters, H M D A, causes heartburn among lenders. This is understandable because HMDA is associated with...
What is a Low Denial Rate Really Telling You?
Here’s an observation worth considering: A low denial rate irrespective of prohibited bases does not in itself ensure that denial disparities by prohibited bases will disappear. In fact, that low denial rate could be a warning that other issues exist, and if the...
3 Reasons to Go Beyond the HMDA Edit Checks before submission
As the year 2021 winds down, it is time to start thinking about ensuring that your HMDA submission is ready to be filed by March 1, 2022. Before the end of this year Compliance Officers, and those ultimately responsible for the HMDA submission signoff, should...
Approaches to Peer Analysis in LendingPatterns™
One of the great features of LendingPatterns™ is that any lender’s diverse lending performance can be analyzed in the context of other lenders in the same market. This is the only way a given lender’s performance can be said to be above or below...
Download 10 Blind Spots In Fair Lending Risk Management
Appraisals, collateral denials, and the potential for discrimination
Freddie Mac recently released a study Research Note pdf based on their analysis of appraisal valuations. It’s worth taking a look. The following sentence from the report summarizes the findings: Our preliminary modeling results suggest that even when taking...
5 Fair Lending Myths Dispelled
After a long career in mortgage finance and fair lending I’ve attended many panels, workshops, and conferences on fair lending. All too frequently at these events, I hear someone from the audience or even a panelist declare a “fair lending myth.” A fair...
Optimize Your HMDA Fair Lending Resources with 6 Key Factors
Optimize Your HMDA Fair Lending Resources with 6 Key Factors Lenders often face the questions, "What resources do I need to manage fair lending?" and "how much should I budget?" The truth is there is no standard answer to these questions regarding effective fair...
What’s the point of fair lending monitoring?
In my experience, there are more lenders who do little to nothing to monitor fair lending than those who actively manage it. Those that do less tend to be independent mortgage companies rather than depository institutions. I believe there are several...
Minimizing Redlining Risk: Questions Lenders Need to be Able to Answer (Part 2)
Recent lawsuits to enforce the federal fair housing laws should serve as strong signals to lenders of an aggressive stance the government is taking regarding the enforcement of redlining under the federal fair lending laws. In Part 1, I highlighted the...