One of the largest banks in the nation just got penalized for filing inaccurate HMDA data. Are you confident that YOUR data is accurate?
It was announced on November 28, 2023, that Bank of America was fined $12 million by the Consumer Financial Protection Bureau for providing false information about mortgage applicants to the government. Over four years, their loan officers didn't ask certain required demographic questions and then inaccurately reported that applicants chose not to respond. The bank must pay into a relief fund and ensure compliance. These actions violated the Home Mortgage Disclosure Act, which mandates reporting of applicant data, including the race, ethnicity, and gender of applicants. The CFPB found Bank of America falsely reported applicant refusals to provide information and failed to oversee accurate data collection by loan officers.
What do you say when an examiner asks: What do you do for Fair Lending Data Analysis?
We don’t use the “F” word around here and don’t have a Fair Lending program.
Uh, what are you talking about?
Holy smoke Batman, we don’t have a holy Fair Lending program
We have a comprehensive Fair Lending program that includes data analysis and regression testing, and take actionable steps to mitigate any outlying data. The data goes to the Board of Directors for their understanding, and we make efforts to ensure we’re deploying best practices when it comes to our Fair Lending practices.
To find out more about the do's and don'ts of Fair Lending, check out our article.
In the spirit of December, MQMR dedicated time to discovering and embrace the many holidays celebrated by our diverse team. It was a wonderful opportunity to learn about the unique traditions and customs that make this season so special for each of our teammates. Check out the holidays that bring joy and meaning to our MQMR family!