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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...
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...
Easy Way to Analyze PPP Loans – Small Business Lending Analysis
We have been fielding interesting questions from our Fair Lending Magic™ subscribers who are preparing information for monthly CRA and fair lending committees about SBA loans in the pipeline. As we all know, the SBA Paycheck Protection Program is a loan designed to...
What the 2019 HMDA Data Tells us About Credit Decisioning
All lenders can recite the 5 C’s of credit backward and forward as easily as reciting the ABCs. However, not as easy is determining the risk of loss and deciding whether to accept or not to accept the risk. Lenders must objectively weigh the importance and evaluate...
Differences between regions in the percent of loans eligible for CARES Act
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, and contains provisions to allow borrowers with federally backed mortgages to request temporary loan forbearance for up to 180 days. In addition, the borrowers...
Helping Housing Groups Understand the Impact of the Current Situation
I have been fielding questions from several housing groups who are trying to understand the implications of the current situation on their local area. As we all know, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27,...
Data Integrity in 2019 Modified HMDA LARs
Two months ago, I wrote about data quality issues that I had seen in the 2018 public HMDA dataset. It turns out that HMDA data quality issues persist in 2019. LendingPatterns™ quickly revealed income reporting issues in the LAR. As an example, for one lender, the...
2019 Refinancing Uptick by the Numbers
The 2019 uptick in refinancings has been well-documented in the media and by mortgage trade organizations. LendingPatterns™ can slice and dice the HMDA data to shed additional light on this increase. In brief, at a high level, I am seeing a 90.2% increase in the...
Don’t Let Reckless Decisions Today Become Tomorrow’s Fair Servicing Compliance Issues
In this current volatile economic environment caused by a public health crisis, mortgage borrowers may have difficulty making mortgage payments. The OCC has directed banks to be flexible with such borrowers. The GSEs have encouraged forbearance and halted...