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Create your own early look using competitors’ 2018 HMDA LARs
At ComplianceTech, we love data analysis, so last Friday’s release of new HMDA data was a truly exciting day. Unfortunately, we will have to wait until the release of the CFPB “snapshot” data for the full data to be in LendingPatterns(TM). Those who are really anxious to look at their competitors’ data can download the…
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Deep Dive into CFPB’s Public Complaint Database
Every company, even the exceptionally good ones, will get a complaint from time-to-time. That said, I think the Consumer Finance Protection Bureau (CFPB) Consumer Complaint Database is a valuable resource for both consumers and our customers who are mortgage lenders. The database at that link contains over 1.2 million complaints related to all types of…
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UDAAP and ECOA Issues in Servicing
Due to the mass amounts of paperwork and legislation, mortgages are a key part of the U.S. financial industry and its most complex feature as well. Here is a quick breakdown of two key compliance concerns related to servicing, one being “fair servicing” ECOA issues and the other being unfair practices under UDAAP: The Challenge…
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Six Fun Facts about Combined Statistical Areas
Combined Statistical Areas (CSAs) are defined in Community Reinvestment Act (CRA) Performance Evaluations (e.g., this one) as “a combination of several adjacent metropolitan statistical areas (MSAs) or micropolitan statistical areas or a mix of the two, which are linked by economic ties.” When describing regional markets for any product, like mortgages, media, etc., people often…
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Mortgage Asset Quality: Use HMDA Data to See How You Compare
All banking professionals are familiar with the acronym CAMELS (Capital Adequacy, Asset Quality, Management, Earnings, Liquidity, Sensitivity), the risk rating system used by bank regulators. HMDA data can play a role in this rating system. Specifically, I’d like to focus on the “A”, Asset Quality. Using HMDA data, we can uncover the unknown risk factors…
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I Have Some Suggestions on HMDA Peer Selection
Defining HMDA peer groups is critical for fair lending benchmark performance evaluation. I’m often asked, “How do regulators define a peer group?” Regulators don’t define peer groups; they offer guidance. For example, they expect lenders to know who their competitors are in their primary lending areas. See below for links to CFPB and FRB guidance.…
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Processing Time and the Quest to Produce Loans Profitably
LendingPatterns™ is more than a HMDA fair lending analysis tool. New in LendingPatterns™ are two pipeline reports that analyze the average processing time by action taken. Even though the reports cannot be used for monitoring secondary hedging/coverage positions, they nevertheless impart valuable insights regarding backroom operation efficiency and decision making. The reports analyze…
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Sizing the market in LendingPatterns™
Before a lender enters a market, it needs to gauge the size of the business opportunity. An accurate understanding of historical loan production in each metro area, county, state, city and even census tract can help size the opportunity and the amount or location of resources needed to seize it. All of this is available…
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Are you Using HMDA Data for Strategic Planning? You Should Be
As a mortgage compliance professional you know your fair lending responsibility as it relates to HMDA, but I want to go beyond and discuss how to use HMDA data for strategic planning. If you are concerned with corporate growth and development, then you know this is more than a check the box exercise. Done with…