We have discussed previously some of the limitations of regression analysis and the importance of an appropriate sample. In today’s post we delve a little deeper into these issues and provide a broader perspective to amplify these points.
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Historically, business lending has not been the focus of fair lending reviews during bank examinations. The focus is usually on HMDA reportable applications since government monitoring information (GMI) is available and, therefore, protected and non-protected classes status is readily identifiable. How is that changing today?
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Evaluating redlining risk can take a number of forms and methods. In a recent webinar by the FDIC, the agency reaffirmed and provided more detail about a bank’s “REMA”, or Reasonably Expected Market Area.
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Commercial banks are required under the Community Reinvestment Act (CRA) to serve all segments of the communities in which they operate. This includes making loans to areas and individuals of all income levels, and particularly low and moderate income communities and persons.
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The FDIC held a meeting of the Advisory Committee on Community Banking on Wednesday, July 12.
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A question that often arises in fair lending regression analysis of lender loan decisioning practices is how special case loans are handled.
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The Fed has increased interest rates 3 times now since December of 2015 resulting in an increase in the Fed Funds Rate of 75 basis points. As rates have been low for a long period of time, the spread between a bank’s cost of funds and the interest rates charged on loans has been […]
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A recent economic report from the New York Federal Reserve indicates that loan payment delinquencies for household debt reflected increases in the first quarter of 2017.
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As we have discussed in previous posts, fair lending regression analysis has become widely used for evaluation of lender practices. While a comprehensive discussion on the subject is unnecessary certainly beyond a blog post, it is important to understand limitations when such analyses are applied to such a critical issue as fair lending.
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A tension exists between a bank meeting its CRA obligations and compliance with other fair lending laws and regulations. This can sometimes present a bank with conflicting priorities.
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