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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...
Minimizing Redlining Risk: Questions Lenders Need to be Able to Answer (Part 1)
Lawsuits advanced by the U.S. Department of Justice (DOJ) and the Consumer Financial Protection Bureau (CFPB) are strong signals to lenders of an aggressive stance the government is taking regarding the enforcement of redlining under the federal fair lending...
7 Criticisms I have heard about Fair Lending Software Vendors
Several prospective customers recently shared specific things with me that they wish their fair lending software could do. They contacted me to set up a time to discuss their concerns and learn about ComplianceTech’s web-based suite of software for HMDA, CRA,...
Auto Fair Lending: Do you monitor Dealer Markup?
The recent fair lending settlement announced by the New York State Department of Banking related to auto loans should put all auto lenders on notice. According to the settlement in New York State, two lenders failed to monitor automobile dealers that were...
HMDA Outliers: Does your credit union stand out in the crowd?
The term “HMDA Outlier'' is used by the National Credit Union Administration (NCUA) and other regulatory agencies to describe part of their criteria for selecting financial institutions for fair lending reviews. Unfortunately, it can be a daunting task for a...