Answer:
In some cases, yes. However more often they will also look at peers, generally lenders with 50% to 200% of your HMDA applications or originations. This eliminates the mega nationwide lenders with infinite resources and the i-2 lenders. Also, for actions taken, they will also compare the results, as you are all generally drawing on the same pool of applicants. Big differences in percentages causes them to try and identify why. See some of our sample reports now.
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