PART I: OVERVIEW.COPYRIGHT © 1993 ESSENTIAL INFORMATION
- What the Fair Lending laws require.
- Key findings.
- Recommended agency enforcement actions.
PART II: SELECTION OF METRO AREAS AND MINORITY NEIGHBORHOODS.
- Selection of the 16 metro areas.
- Definition of minority neighborhood.
PART III: STUDY RESULTS AND INTERPRETATION.
- Worst case lending patterns: The most common variations.
- Worst case lending patterns shaped by minority population concentration and composition.
- Decatur Federal S&L's lending pattern in Atlanta, Georgia
- Lack of applications from minority neighborhoods.
- Presumption of no marketing effort.
- Substantial mortgage loan market in minority neighborhoods.
- Major lenders can serve home financing needs of minority neighborhoods.
- Injury to minority persons and minority neighborhoods.
- Exclusionary lending criteria contribute to worst case lending patterns.
- Consolidation of home purchase loans made by affiliates.
- Consolidation of loan originations and loan purchases.
- Mortgage companies dominate the list of worst case lenders.
PART IV: RECOMMENDATIONS FOR STRENGTHENING FAIR LENDING ENFORCEMENT.
- The federal Fair Lending enforcement agencies should routinely determine each mortgage lender's effective lending territory and assess from a Fair Lending perspective whether minority neighborhoods have been excluded from this territory or underserved.
- The federal Fair Lending enforcement agencies should routinely create and review lending pattern maps for individual mortgage lenders as an aid in defining effective lending territories and assessing whether there is evidence of racial redlining.
- In implementing the ban on racial redlining, the federal Fair Lending enforcement agencies should fully develop the "disparate impact" or "effects test" theory of discrimination.
- HUD should promulgate new Fair Lending regulations that would establish an effective enforcement strategy against racial redlining.
- The federal Fair Lending enforcement agencies should adopt a policy statement that would establish a presumption against consolidating home purchase loans made by affiliated lenders for Fair Lending evaluation purposes.
- The federal Fair Lending enforcement agencies should adopt a policy statement that would establish a presumption against consolidating loan originations and loan purchases for Fair Lending evaluation purposes.
PART V: RECOMMENDATIONS FOR CONGRESS.
- The Congress should conduct hearings on a broad spectrum of Fair Lending issues.
- Congress should enact legislation to facilitate creating state-based financial consumers associations.
PART VI: THE STUDY DESIGN
- Data sources: HMDA and Census Bureau.
- Selection of lenders for mapping.
- Designation of worst case lending patterns and affirmative lending patterns
- Lending patterns and cWorresponding HMDA statistics.
- Inventory of lending pattern maps and Census data maps.
- Design of lending pattern maps.
- Technical data processing and mapping issues.