Blog
List of articles
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...
10 Blind Spots in Fair Lending Risk Management
Normally, when one thinks of the term “blind spot” our mind immediately goes to driving a car and what we can’t see in either our rear-view or side-view mirrors. What we cannot see is affected by our past driving experience, our vantage point or our location in...
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...
What LendingPatterns™ Can Show You About the New York Community Bank and Flagstar Merger
The announcement of the New York Community Bank and Flagstar merger on April 26, 2021 has me thinking about its impact on the industry as well as what lenders might learn by looking at the data behind the merger. The good news is that it is easy to create pseudo bank...
Loan volume growth, interest rate cuts, and third-party lending
In my previous blog, I wrote about the drivers of Fannie Mae’s increased purchasing activity. This blog will explore the extent to which that growth was driven by declining interest rates. I want to show a chart that distinguishes transactions based on whether the...
Digging into growth trends in the 2020 HMDA Modified LAR data
The American public has known for some time that 2020 was a year of dramatically increased mortgage lending activity. The Mortgage Bankers Association published its own survey and forecast data, and the GSEs reported on their increased levels of mortgage loan...
2020 Year-in-Review HMDA, Fair Lending, and CRA Developments
As we ring in the new year, it is helpful to recap what has happened in 2020 on three different fronts: HMDA, fair lending, and CRA. I count eight important developments. These are listed in no particular order below: 1. Modifications to the 2020 and 2021 HMDA Filing...
A Holistic View of Fair Lending: The Loan Lifecycle
We are pleased to post a blog written by a guest author. As a former examiner with the FDIC, Tory Haggerty has a lot to share and offers some practical advice on his view of fair lending monitoring and identifying hidden risks. He poses critical questions...
It’s All About Underwriting and Pricing Exceptions
One key component to any fair lending monitoring program is robust monitoring of underwriting and pricing exceptions. The Interagency Fair Lending Examinations Procedures indicate that institutions face increased fair lending risk if internal policies are vague with...
How Well do You Really Know Your HMDA Peers?
Questionable HMDA annual income values can compromise the integrity of fair lending and Community Reinvestment Act (CRA) analysis. This field seems straightforward, right? The lender reports the “gross annual income relied on in making the credit decision”. The lender...
Interesting Facts About the 2019 HMDA Data
The CFPB released the final 2019 National Snapshot HMDA data about three months earlier than last year, and ComplianceTech has refreshed LendingPatterns™ with the latest data. An initial review of the data reveals the following interesting facts. There were a total...
The COVID-19 Forbearance Moratorium Enlarges the Wound Caused by the Lack of Homeownership in Black America
Maurice Jourdain-Earl, Managing Director of ComplianceTech published this article on LinkedIn: The COVID-19 Forbearance Moratorium Enlarges the Wound Caused by the Lack of Homeownership in Black America. You can access the full article by clicking this...
Fair Lending: Expectations vs. Reality
Inaccurate information held by organizations regarding fair lending risk management can hinder them from successfully managing that risk. Today, we’re looking at five prevalent expectations within the industry and the reality for each. Expectation #1: Written policies...