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Consolidating Race for Fair Lending Analysis |
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We are in the process of analyzing our HMDA data to determine if Fair Lending practices are being observed and have found competing arguments about how to consolidate multiple race codes to obtain a single race for analysis. The two schools of thought seem to be: 1) a. search for a race of african american anywhere in the 5 race codes of the applicant or co-applicant and use that b. if ethnicty is hispanic for applicant or co-applicant use that, otherwise use the first race provided. c. search for a race of native american anywhere in the 5 race codes of the applicant or co-applicant and use that d. search for a race of asian anywhere in the 5 race codes of the applicant or co-applicant and use that e. if the race information is missing or blank it is deemed as not applicable, otherwise the race is white 2) Use the FFIEC method of determing race which is used on the disclosure tables. Our thoughts are the FFIEC method is more offical, however several interest groups seem to prefer the competing method. Does anyone out there hace any idea which is the more preferred method? Crystal Jackson The FFIEC method is the most accurate for regulators. |
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