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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. …
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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 the risk of loss using ratios and thresholds. …
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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 have the right to apply for an extension of another 180 days of…
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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, 2020, and contains provisions to allow borrowers with federally backed…
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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 average reported income for a large batch of loans…
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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 dollar volume of refinancing originations, compared to 2018 ($1.203 trilllion…
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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 foreclosure activity. Like in the most recent financial crisis, mortgage servicers’ handling of loss mitigation requests will…
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Mortgage Loans: To Sell or Not to Sell
We decided to take a look at lenders that have the option to sell loans as well as portfolio to see what we can learn about their decisioning and selection process. Happily, we have access to LendingPatterns™. The robust peer selection tool allowed us to create a custom peer group of 2,461 lenders that either…
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Elements to Consider Before Selecting a Fair Lending Analytical Tool
When it comes to evaluating compliance with fair lending laws, you want a tool that will conduct widespread and effective evaluations based on the FFIEC risk factors. Although there are many tools on the market, be sure to consider these 6 elements before selecting a fair lending analytical tool. 1. Administration and Credentials As you’re…