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Brief Summary of 2021 Modified HMDA LARs
HMDA Data Summary The total number of rows in the 2021 Modified LARs (25.96 million) and the number of originated transactions (14.89 million), while very high by historical standards, are both around two percentage points higher than the 2020 Snapshot data. What is a more intriguing trend is the apparent consolidation in the mortgage industry.…
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HMDA Data and Strategic Planning for Mortgage Lenders
As a mortgage compliance professional, you know your fair lending responsibility related to HMDA; but I want to go beyond and discuss how to use HMDA data for strategic planning. If you are concerned with corporate growth and development, then you know this is more than a check-the-box exercise. Done with attention and thought, the…
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2021 Year-in-Review of HMDA, Fair Lending, and CRA Developments
As we ring in the new year, it is helpful to recap what has happened in 2021 on three different fronts: HMDA, fair lending, and CRA (the Community Reinvestment Act). I count eight important developments. These are listed in no particular order below: 1. HMDA Filing Instruction Guide (FIG) updates The most recent revision to…
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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 a useful picture of the overall market. ComplianceTech…
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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 and your business. Here is a brief update about…
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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 systems (LOS) or physical loan documents. There are several reasons why you…
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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 and/or ethnicity are reported as…
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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 data to quantify fair lending risk in several ways: Disparity Ratios. Comparing decision or…
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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 compliance, regulation, race, and lawsuits. HMDA data are a blessing to the mortgage…
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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 denial rate is low enough, it would be a red flag that…