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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 use this time to make sure that the HMDA data…
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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 expectations. Sometimes this is referred to as comparing a lender against…
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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 structural and neighborhood characteristics into consideration, a property is more likely to receive an appraisal lower than…
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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 lending myth is a statement about HMDA, ECOA, and FH Act regulatory…
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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 lending analysis. The human, technological, and monetary resources needed to handle…
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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 reasons for this outcome: A) Culture and Traditions: Prior to Dodd-Frank independent mortgage companies…
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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 following five questions that every lender should be able to ask themselves and answer…
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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 laws. The Hudson City and BancorpSouth cases settled in 2015 and 2016, respectively, are striking for…
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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, and fair lending analysis. Since many voiced the same concerns, I thought it would…