Anatomy of a Fair Lending Exam: The Uses and Limitations of Statistics
Posted: 23 Apr 2002
In this paper, we examine how statistical analysis is used to help conduct fair lending compliance examinations. We present a case study of an actual fair lending examination of a large mortgage lender, illustrating how statistical techniques are used to focus examiner efforts. Our case also highlights the limitations inherent in statistical analysis of discrimination. The study suggests that statistical analysis and the more-traditional comparative file reviews complement one another in the overall examination process, offsetting some of the limitations inherent in each.
Keywords: mortgage discrimination, fair lending, bank regulation
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