-
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 charging minorities more in discretionary Dealer Markups than borrowers identified as non-Hispanic White.…
-
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 Compliance Officer to get a handle on their Home Mortgage Disclosure Act (HMDA) data and…
-
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 mergers using LendingPatterns™, ComplianceTech’s…
-
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 HMDA-reporting institution is doing business with a third party, but first…
-
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 purchasing. Now that the CFPB has released its “modified” HMDA LAR data on March…
-
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 Instruction Guides (FIGs) The 2020 FIG was…
-
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 that every compliance officer should be able to answer. …
-
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 respect to the granting of exceptions. Written policies should be in place that explain the process for submitting, evaluating, approving,…
-
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 should “round all dollar amounts to the nearest thousand”. The 2020 Filing Instruction Guide (FIG) also…
-
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 of 5,508 lenders who reported over 17.5 million mortgage LAR records. Of those records:…