The FFIEC announced last week that 2016 Home Mortgage Disclosure Act (HMDA) data for reporting institutions is now publicly available for calendar year 2016. Enacted in 1975, the Home Mortgage Disclosure Act requires lenders to report mortgage applications received during the prior calendar year.
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Understanding and managing exceptions to loan policy is a critical component of a financial institution’s fair lending risk management. It is important to understand how exceptions are defined and how they are tracked and managed. In today’s post, we focus on the former and will discuss options for management in the future.
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As we have noted previously, banks across the board are performing better in regard to earnings. This is in part due to an improving economy and consumer confidence, but also to the rising rate environment. Although rates are still at historic lows, prime is one percentage point above the 10 year low of 3.25 and […]
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One of the challenges in analyzing consumer data for fair lending is the lack of protected-class status, such as race, gender and ethnicity. There are solutions for approximating this data, but they offer their own challenges in turn.
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There are often game-changers in the world of regulatory risk.
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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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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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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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A fundamental assumption in fair lending regression analysis is that the model is correctly specified and contains all the relevant variables.
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