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#2263883 - 12/21/21 06:54 PM HMDA Analysis of low to mod activity
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 731
Tennessee
I'm new to CRA and have not officially been named in charge of it....

What are some things I can look at to explain a decrease in lending activity for a low-to mod category....

For example if our HMDA loan originations have been decreasing percentage wise for low to mod income census tracts...or low to mod income borrowers....

I'm not sure if there is some public economic data to review that could help explain any decreasing patterns....

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#2263885 - 12/21/21 07:25 PM Re: HMDA Analysis of low to mod activity Compliance504
CD Banker Offline
New Poster
Joined: Feb 2019
Posts: 17
The first place you can look is at peer data - either individual banks in your area that are similar or even aggregate data. If you use software, you can find it there. Are peers seeing a decrease similar to what you are seeing. The other thing to consider is that it's typical that when overall volume is up, LMI % often goes down. This is especially true in a high refi climate. If your numbers are going down at a rate greater than peers, you will need to address it or be able to explain it.

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#2263892 - 12/21/21 07:55 PM Re: HMDA Analysis of low to mod activity Compliance504
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 731
Tennessee
Thank you!!!!!

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#2263894 - 12/21/21 08:02 PM Re: HMDA Analysis of low to mod activity Compliance504
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 731
Tennessee
CD...I sent you a PM...

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#2264010 - 12/24/21 12:22 AM Re: HMDA Analysis of low to mod activity Compliance504
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,133
Connecticut
It's very important to analyze and understand your performance and be able to explain to examiners your results. There has been a trend for more than a decade for non-bank lenders to dominate the residential mortgage market. You really should have all the HMDA market data for your AA including market rank and share, who the lenders are, a breakout of the competitive situation in the market as well as data about the borrowers in the market. What are the characteristics of borrowers in the market? Is there a large Hispanic community? Do you have bilingual mortgage officers? How much impact do the non-bank lenders have on the market.
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