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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…
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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 HMDA-reporting institution is doing business with a third party, but first…
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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…
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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…
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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. …
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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,…
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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…
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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:…
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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 ensure that an organization doesn’t need to worry about fair lending because it’s entirely protected. Reality: Although it’s…
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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 provide a direct incentive for small businesses to keep their workers on the payroll. …