Based on information gained from interviews, HMDA data, and testing,
the ICRC selected 64 lenders for comparative file analysis. The
ICRC contacted all 64 and asked whether they would permit ICRC
staff to examine their mortgage loan files. Three institutions
agreed, a mortgage company and two credit unions -- located in
Cedar Rapids, Dubuque, and Waterloo.
Conducting a comparative file analysis can mean reviewing loan
files of rejected minority applicants and comparing those rejected
files with files of accepted, similarly situated, white applicants,
to see whether minority applicants are held to higher underwriting
standards, given less help in qualifying, or otherwise treated
differently in the application and decision-making process.
Conducting a comparative file analysis can also mean reviewing
loan files of accepted minority applicants and comparing those
accepted files with files of accepted white applicants to determine
whether similarly situated minority applicants are required to
make larger down payments, charged higher rates or fees, or required
to have additional credit history documentation.
Cedar Rapids Lender. The ICRC reviewed all 12 of the minority
mortgage loan applications submitted in 1995. Ten of the 12 applications
were accepted and 2 were withdrawn. For each of the 12 minority
applications, the ICRC selected and reviewed 5 accepted white
applications. The white applications selected matched the particular
minority application in loan amount, loan product, loan officer,
and time period. The ICRC compared each of the minority files
with the 5 white files, and found no differences in lender treatment
based on race or national origin.
Dubuque Lender. The ICRC reviewed all 3 of the minority
applications submitted in 1995, all of which were accepted. For
each of the 3 minority applications, the ICRC selected and reviewed
4 accepted white applications, again similar in loan amount, loan
product, and time period. The ICRC compared each of the minority
files with the 4 white files, and found no different treatment.
Waterloo Lender. The ICRC was given only a sample of the
minority and white applications submitted in 1995 and 1996. The
ICRC was not allowed to select white files comparable to the minority
files in amount or product.