The authors discuss whether HMDA data tells a complete story of a lender’s credit decision.
The Home Mortgage Disclosure Act (HMDA) and subsequent amendments expanding the universe of application data collected were important steps forward in fair lending transparency. But does HMDA data tell a complete story of a lender’s credit decision?
In this article on detecting discriminatory mortgage lending, authors Abe Chernin, Shane Oka, and Kevin Oswald discuss the importance of controlling for applicant characteristics, the limitations of HMDA data’s ability to do so, and the need for manual loan file review to confirm indications of potential discriminatory lending.
This article was originally published by Law360 in November 2025.
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