Comparative File Analysis




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 Ten of the 12 applications were accepted and 2 were withdrawn.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.

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