Representative Engagements

Fair Lending Performance Review

We performed an analysis of the bank’s HMDA lending activity to identify 1) differences in levels of assistance based on the timing of decisions and final disposition of applications; 2) disparities in application outcomes including origination, denial, and non-decisioned applications; 3) pricing variances related to the frequency and magnitude of differences in APR and rate spread; 4)  steering of applicants to particular products or sales channels; and 5) redlining analysis to identify potential geographic and demographic gaps in higher minority geographies. The analyses provided the bank the information necessary to effectively manage fair lending performance risk.