How to Analyze Fair Lending Compliance: Practical Tools
Your HMDA-LAR data is the ground floor of a fair lending examination, and your regulators are performing detailed statistical analysis in preparation for the exam. It is a goldmine of information simply because it contains demographic information of applicants and borrowers. Performing analysis of HMDA data is no longer a best practice; it is an expectation of examiners. They expect you to understand your own data and be able to apply a risk-based focus in your efforts.
The stakes are only getting higher: the Dodd-Frank Act contains provisions requiring additional HMDA data to be collected and submitted in the years to come, and in the years to come we'll be collecting and submitting data on commercial applications, as well. Understanding your data is no longer a "nice-to-have"; it's a necessity.
But what does this mean? How to best do this? This program explores ways to use HMDA data in various types of analysis's. This isn't meant only for larger institutions, either. There are many tools that even the smallest community banks can (and should) utilize. Many of these analysis's can be performed with just Excel. But in today's strict fair lending examination environment, understanding your own data is a necessity.
Covered Topics Include:
- Collecting the information you need (it's more than just LAR data)
- Basic calculations to run to identify areas for further analysis: disparity ratios, t-values, and more
- Analyzing your data by "slices"
- Identifying problem areas
- Reviewing peer data
- Examples of tables, calculations and comparisons to run
- Analyzing pricing information
- Examiner expectations regarding additional data elements
- Identifying and analyzing "outliers"
- Regression analysis, matched pairs/comparative file review, and individual file review
- Service level analysis
- Analyzing foreclosures, modifications, and other distressed situations
- What to do with the information when you're done – reporting and escalation
Who Should Attend?
The program is designed for loan department management, compliance officers, testers, and auditors. Bank counsel and any other department and/or personnel concerned with fair lending performance will benefit by this webinar's information. This program will provide the necessary tools to perform analysis of HMDA and fair lending data.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Senior Vice President and Compliance Manager for a large financial institution in Ohio. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at dozens of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
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