Fair lending concerns are one of the dominant risks lenders face in regard to their business operations. Although larger lenders typically have significant resources in place to mitigate these risks, and there has been an emphasis in the last decade on quantitative methods for fair lending evaluation, there remains a great deal of subjectivity in […]
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Below, we provide a summary of the recently released 2019 HMDA data, and keys for understanding the importance of these data. The Basics Enacted by Congress in 1975, and implemented by Regulation C, the Home Mortgage Disclosure Act (HMDA) is considered “the most comprehensive, publicly available information on mortgage market activity.” Its purpose is to […]
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The term “Information Age” probably pre-dates many who are reading this post, possibly originating as early as the 1970’s with the proliferation of computer technology. From the mainframe era, to PC’s, laptops, personal devices and smart phones, technology continues to shape our world at a seemingly ever increasing rate. This is all augmented by the […]
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The Bureau of Consumer Financial Protection issued its seventh Fair Lending Report to Congress. The report, released June 28, 2019, describes the Bureau’s fair lending activities in prioritization, supervision, enforcement, rulemaking, interagency coordination, and outreach for calendar year 2018.
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We have discussed previously in various posts some of the challenges of using regression and other statistical methods for fair lending reviews as well as the current emphasis on quantitative methods. Over the last 10 years, the regulatory and enforcement agencies as well as institutions have been gravitating more and more towards statistical methods when […]
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In previous posts we have emphasized the importance of customer service as an aspect of managing fair lending risk. Since fair lending deals primarily with treatment of applicants, and the agencies recognize that discrimination can take place at any aspect of the transaction, inconsistency in levels of service could constitute fair lending risk. Consequently, having […]
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In a speech earlier this year, FDIC Chair Jelena McWilliams provided some insights concerning her vision with regard to bank regulation.
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As a New Orleans native, we are very proud of our cooking and food – and, for good reason. My grandmother had to be one of the best cooks that ever walked the face of the earth. No matter the dish, whatever she was serving up was unbelievably good.
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A regulatory examination of lending activity, whether fair lending related or safety and soundness, always focuses on data. Data integrity notwithstanding (which is another blog post entirely), such data is a function of (2) things: (1) policies and (2) actual practices. The interaction of these two forces creates the lending data that will be […]
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All of us are familiar with the term “perfect storm.” A perfect storm can be defined as the occurrence of a highly improbable event. In the context of the perfect storm, the event is improbable because a combination of factors or conditions have to occur or exist either simultaneously or in a particular sequence in […]
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