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Expected Loss of Rate Spread Data Should Hurt Fair Lending Pricing Analysis
The August 31, 2018 HMDA rule helped clarify the 2018 reporting requirements for banks and credit unions that are minor players in the mortgage market. However, this rule could adversely affect the rate spread data used in fair lending pricing analysis. Rate spread is the difference on a consumer loan between the APR and the…
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Where are the biggest movers in 2018 median family income stats?
On August 16, the Federal Financial Institutions Examination Council (FFIEC) released 2018 median family income (MFI) statistics for metropolitan areas to be used in fair lending and CRA analysis. This blog presents some interesting discoveries when comparing 2018 to 2017 MFIs. (The 2018 MFIs are live in Fair Lending Magic™ and will be live in…
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2018 HMDA and Fair Lending Underwriting Analysis
As the first quarter of 2018 ends, many compliance officers will be interested in doing a preliminary analysis of their 2018 HMDA data. This blog focuses on how underwriting analysis changes going forward. If you have been doing a thorough analysis, the best advice is to keep doing what you have been doing. And if…