Underwriting Disparity Analysis

•  Underwriting App/Deny-(3 Loan Programs)

The Underwriting-Approve/Deny reports identify individual applicants that may be victims of discrimination. The reports are not conclusive, with respect to identifying victims, but they isolate which loan files should be investigated further. In addition, the Underwriting-Approve/Deny reports are structured to display additional risk characteristics about both the control and target group applicants to potentially rule out discrimination as the reason for the difference in outcomes.

The Underwriting-Approve/Deny reports isolate and match the similarity situated target group applications that were denied with the control group applications that were approved. The matched pairs are viewed side by side in an effort to determine why applicants with equal to or better than comparison criteria outcomes were treated differently.

•  Benchmark/Overlap

The Benchmark Overlap report matches a Denied Target group applicant with Approved control group applicants even though the former is equally or better qualified than the latter based on a single (benchmark) comparison criterion. The Benchmark Overlap report is less stringent than the Side by Side report, which contains several comparison criteria, but satisfies the standard set by the Inter Agency Fair Lending Examination Procedure.

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