Cover-HMDA Portfolio Fair Lending Analysis 111912...fair lending risk analysis reports hmda...
Transcript of Cover-HMDA Portfolio Fair Lending Analysis 111912...fair lending risk analysis reports hmda...
FAIR LENDING RISK ANALYSIS REPORTS HMDA PORTFOLIO w9±L9²
61 NORTH PLAINS INDUSTRIAL RD, PBN 174 WALLINGFORD, CT 06492 www.geodatavision.com (203) 237‐1332
GDV BANK
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Fair Lending Risk Analysis Reports
Reports are numbered from Series 100 through Series 200. The 100 Series of Reports contains statistical comparisons of applications processed by the Bank. The 100 Series of Reports is intended to provide insight into potential Fair Lending Risk though statistical comparisons between groups of Protected Class Applicants and Control Group Applicants to reveal different patterns of outcomes or processes.
Within the Series 100 ‐127 Reports are 3 classes of reports: "a","b"and "c". The first report in each group, "a", compares all minority classes to the control group. The second Fair Lending report in each group "b", measures the percentages of actions taken between the ethnic and race subgroup applicants to the control group. The third Fair Lending report in each group "c" measures the percentages of gender ‐ female applicants to male applicants actions taken.
Reports 100 through 108 reveal outcome variance comparisons for home purchase mortgages, refinance mortgages and home improvement loans for 1st, then junior mortgages.
Reports numbered 130 through 137 measure red lining risk with respect to Low‐ and Moderate‐income tracts and Minority Tracts.
Reports 138 and 139 depict rate spread differences by comparison of minority and female applications to Control Group applications.
Reports 140 and 141 show processing time differences between Protected Class applicants and Control Group applicants. Reports 142 through 144 compare mortgage actions of the bank to various assssment area demographics and competitors' actions. Reports 150-151 compare interest APR's to protected classes.
The Reports in the 200 Series contain record comparisons between individual Protected Class Applications and Control Group Applications with similar credit characteristics in order to identify potential outcome or treatment disparities that merit further investigation.
Explanations of the calculations appear in the footnotes on each page. "Dropouts" reflect lost opportunities, i.e. loans that were approved but not accepted by borrowers, withdrawn by the applicant before the bank made a decision or closed for incompleteness.
There is one important caveat ‐ underwriting is an art, not a science. The decision to make or deny a loan is based on many factors, including the intent and ability to repay the obligation and the equity that the applicant puts down. The numbers reflect percentage differences and only by carefully comparing actual files could it be determined if the decision process was consistent.
FAIR LENDING RISK ANALYSIS ‐ REPORT DESCRIPTIONS
Series 100‐127 (as appropriate) Reports Measure Outcome Variance: “a” Reports ‐ all applications for that particular category “b” Reports ‐ comparisons of ethnic and racial minorities to white applicants “c” Reports ‐ comparisons of female to male applicants Series 100 to 127 Reports repeat statistical comparisons based on: loan type; loan purpose; lien
Series 130‐137 Reports ‐ Redlining Risk Analysis Report 130: By Tract Income Class ‐ Comparing origination, denial and dropout rates ‐ tract incomeReport 131: By Minority Tracts ‐ Comparing origination, denial and dropout rates ‐ tract minority statusReport 132: Denials in LMI Tracts Report 133: Denials in Minority Tracts Report 134: By LMI Tracts ‐ no client Bank mortgage activity compared to market Report 135: By Minority Tracts ‐ no client Bank mortgage activity compared to marketReport 136: By LMI Tracts ‐ housing opportunities in tracts with no Bank mortgages Report 137: By Minority Tracts ‐ housing opportunities in tracts with no Bank mortgages
Series 138‐139 Reports ‐ Rate Spread Analysis Report 138: Rate Spread Minority originations with critical parameters (DTI, LTV, etc.) Report 139: Rate Spread Female originations with critical parameters (DTI, LTV, etc.)
Series 140‐151 Reports Report 140: Processing Time Comparisons for Minority Applications Report 141: Processing Time Comparisons based on Gender Report 142: Action Type ComparisonsReport 143: Mortgage Activity Compared to Market Demographics Report 144: Mortgage Activity Compared to Competitors 150-151 Comparison by APR's.
Series 200‐202 Reports ‐ Record Comparisons ‐ Minority Applications Denied “a” Reports ‐ ethnic and racial minorities to white applicants“b” Reports ‐ female to male applicantsReport 200: Denied for credit compared to Non‐Minority originations with lower credit scoreReport 201: Denied for income compared to Non‐Minority originations with higher debt to income ratioReport 202: Denied for collateral compared to Non‐Minority originations with higher loan to value.ratio
The GeoDataVision Fair Lending Risk Analysis Reports can also be tailored to incorporate additional loan types including FHA, VA and FHA/RHS mortgage applications. If your institution has programs for these types of loans, we will include them in the analysis.
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Report 100a (Summary of all applications and liens)
Fair Lending Variance Summary GDV Bank Records
Focal Points: Mortgage Type: AllMortgage Purpose: AllLien Position: All
Minority Originations
Minority Denials
Minority Dropouts
Minority Applications
White Originations
White Denials
White Dropouts
White Applications
GDV Bank
Minority Origination
Rate
Minority Denial Rate
50 22 1890 55.56% 24.44%
381 82 71534
Minority Dropout Rate
20.00%
White Origination
Rate
71.35%
White Denial Rate
15.36%
White Dropout Rate
13.30%
Outcome Comparisons Origination Incidence Variance
Denial Incidence Variance
Dropout Incidence Variance
Minority "Rate Spread"
Incidence
0.00%
White "Rate Spread"
Incidence
0.79%
"Rate Spread" Incidence Variance
Minority Rate Spread
White Rate Spread
Units
0
3
0.78 1.59 1.50Negative Comparison
Negative Comparison
Negative Comparison
0.00Positive Comparison
Outcomes are compared based on the relative incidence of various outcomes. For example, the relative percentage of minority applications resulting in originations ("Origination Rate") is compared to the relative percentage of white mortgage applications resulting in originations. A perfect correlation is "1", meaning that the same percentage of minority applications were originated as majority applications. Results greater than "1" indicate a higher incidence of minority mortgage applications resulted in the outcome and results less than "1" indicate a lower incidence of minority applications with the outcome. For origination rate comparisons, a high number is a positive comparison whereas for denials, "dropouts" (a combination of: withdrawn, incomplete and approved not accepted) and rate spread a number higher than "1" is an unfavorable ("negative") comparison. "Rate Spread" refers to mortgages whose rate met or exceeded the rate spread threshold as defined by the Regulation.
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 1 Report 100a - Outcome Variance-All Records
Fair Lending Variance Summary Report GDV Bank Records by Minority Classification Focal Points:
Mortgage Type: AllMortgage Purpose: AllLien Position: All
Report 100b - Summary of all Race/Ethnicity
GDV Bank
White Originations
White Denials
White Dropouts
White Applications
20 10 737 54.05% 27.03%
381 82 71534
18.92%
White Origination
Rate
71.35%
White Denial Rate
15.36%
White Dropout Rate
13.30%
Outcome Comparisons Origination Incidence Variance
Denial Incidence Variance
Dropout Incidence Variance
0.00%
White "Rate Spread"
Incidence
0.79%
"Rate Spread" Incidence Variance
White Rate Spread
Units
0
3
0.76 1.76 1.42Negative Comparison
Negative Comparison
Negative Comparison
0.00Positive Comparison
Hispanic
Hispanic Applications
Hispanic Originations
Hispanic Origination
Rate
Hispanic Denials
Hispanic Denial Rate
Hispanic Dropouts
Hispanic Dropout Rate
Hispanic Rate Spread
Units
Hispanic Rate Spread Incidence
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 5 Report 100b - Outcome Variance-All Records by Minority Classification
Outcomes are compared based on the relative incidence of various outcomes. For example, the relative percentage of minority applications resulting in originations ("Origination Rate") is compared to the relative percentage of white mortgage applications resulting in originations. A perfect correlation is "1", meaning that the same percentage of minority applications were originated as majority applications. Results greater than "1" indicate a higher incidence of minority mortgage applications resulted in the outcome and results less than "1" indicate a lower incidence of minority applications with the outcome. For origination rate comparisons, a high number is a positive comparison whereas for denials, "dropouts" (a combination of: withdrawn, incomplete and approved not accepted) and rate spread a number higher than "1" is an unfavorable ("negative") comparison. "Rate Spread" refers to mortgages whose rate met or exceeded the rate spread threshold as defined by the Regulation.
GDV Bank
White Originations
White Denials
White Dropouts
White Applications
19 5 832 59.38% 15.63%
381 82 71534
25.00%
White Origination
Rate
71.35%
White Denial Rate
15.36%
White Dropout Rate
13.30%
Outcome Comparisons Origination Incidence Variance
Denial Incidence Variance
Dropout Incidence Variance
0.00%
White "Rate Spread"
Incidence
0.79%
"Rate Spread" Incidence Variance
White Rate Spread
Units
0
3
0.83 1.02 1.88Negative Comparison
Negative Comparison
Negative Comparison
0.00Positive Comparison
Asian
Asian Applications
Asian Originations
Asian Origination
Rate
Asian Denials
Asian Denial Rate
Asian Dropouts
Asian Dropout Rate
Asian Rate Spread Units
Asian Rate Spread Incidence
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 2 of 5 Report 100b - Outcome Variance-All Records by Minority Classification
Outcomes are compared based on the relative incidence of various outcomes. For example, the relative percentage of minority applications resulting in originations ("Origination Rate") is compared to the relative percentage of white mortgage applications resulting in originations. A perfect correlation is "1", meaning that the same percentage of minority applications were originated as majority applications. Results greater than "1" indicate a higher incidence of minority mortgage applications resulted in the outcome and results less than "1" indicate a lower incidence of minority applications with the outcome. For origination rate comparisons, a high number is a positive comparison whereas for denials, "dropouts" (a combination of: withdrawn, incomplete and approved not accepted) and rate spread a number higher than "1" is an unfavorable ("negative") comparison. "Rate Spread" refers to mortgages whose rate met or exceeded the rate spread threshold as defined by the Regulation.
GDV Bank
White Originations
White Denials
White Dropouts
White Applications
9 6 318 50.00% 33.33%
381 82 71534
16.67%
White Origination
Rate
71.35%
White Denial Rate
15.36%
White Dropout Rate
13.30%
Outcome Comparisons Origination Incidence Variance
Denial Incidence Variance
Dropout Incidence Variance
0.00%
White "Rate Spread"
Incidence
0.79%
"Rate Spread" Incidence Variance
White Rate Spread
Units
0
3
0.70 2.17 1.25Negative Comparison
Negative Comparison
Negative Comparison
0.00Positive Comparison
Black
Black Applications
Black Originations
Black Origination
Rate
Black Denials Black Denial Rate
Black Dropouts
Black Dropout Rate
Black Rate Spread Units
Black Rate Spread Incidence
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 3 of 5 Report 100b - Outcome Variance-All Records by Minority Classification
Outcomes are compared based on the relative incidence of various outcomes. For example, the relative percentage of minority applications resulting in originations ("Origination Rate") is compared to the relative percentage of white mortgage applications resulting in originations. A perfect correlation is "1", meaning that the same percentage of minority applications were originated as majority applications. Results greater than "1" indicate a higher incidence of minority mortgage applications resulted in the outcome and results less than "1" indicate a lower incidence of minority applications with the outcome. For origination rate comparisons, a high number is a positive comparison whereas for denials, "dropouts" (a combination of: withdrawn, incomplete and approved not accepted) and rate spread a number higher than "1" is an unfavorable ("negative") comparison. "Rate Spread" refers to mortgages whose rate met or exceeded the rate spread threshold as defined by the Regulation.
GDV Bank
White Originations
White Denials
White Dropouts
White Applications
2 0 02 100.00% 0.00%
381 82 71534
0.00%
White Origination
Rate
71.35%
White Denial Rate
15.36%
White Dropout Rate
13.30%
Outcome Comparisons Origination Incidence Variance
Denial Incidence Variance
Dropout Incidence Variance
0.00%
White "Rate Spread"
Incidence
0.79%
"Rate Spread" Incidence Variance
White Rate Spread
Units
0
3
1.40 0.00 0.00Positive Comparison
Positive Comparison
Positive Comparison
0.00Positive Comparison
MultiRacial
MultiRacial Applications
MultiRacial Originations
MultiRacial Origination
Rate
MultiRacial Denials
MultiRacial Denial Rate
MultiRacial Dropouts
MultiRacial Dropout Rate
MultiRacial Rate Spread
Units
MultiRacial Rate Spread Incidence
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 4 of 5 Report 100b - Outcome Variance-All Records by Minority Classification
Outcomes are compared based on the relative incidence of various outcomes. For example, the relative percentage of minority applications resulting in originations ("Origination Rate") is compared to the relative percentage of white mortgage applications resulting in originations. A perfect correlation is "1", meaning that the same percentage of minority applications were originated as majority applications. Results greater than "1" indicate a higher incidence of minority mortgage applications resulted in the outcome and results less than "1" indicate a lower incidence of minority applications with the outcome. For origination rate comparisons, a high number is a positive comparison whereas for denials, "dropouts" (a combination of: withdrawn, incomplete and approved not accepted) and rate spread a number higher than "1" is an unfavorable ("negative") comparison. "Rate Spread" refers to mortgages whose rate met or exceeded the rate spread threshold as defined by the Regulation.
GDV Bank
White Originations
White Denials
White Dropouts
White Applications
0 1 01 0.00% 100.00%
381 82 71534
0.00%
White Origination
Rate
71.35%
White Denial Rate
15.36%
White Dropout Rate
13.30%
Outcome Comparisons Origination Incidence Variance
Denial Incidence Variance
Dropout Incidence Variance
NA
White "Rate Spread"
Incidence
0.79%
"Rate Spread" Incidence Variance
White Rate Spread
Units
0
3
0.00 6.51 0.00Negative Comparison
Negative Comparison
Positive Comparison
0.00Positive Comparison
Hawaiian Islander/Pacific Islander
HIPI Applications
HIPI Originations
HIPI Origination
Rate
HIPI Denials HIPI Denial Rate
HIPI Dropouts
HIPI Dropout Rate
HIPI Rate Spread Units
HIPI Rate Spread Incidence
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 5 of 5 Report 100b - Outcome Variance-All Records by Minority Classification
Outcomes are compared based on the relative incidence of various outcomes. For example, the relative percentage of minority applications resulting in originations ("Origination Rate") is compared to the relative percentage of white mortgage applications resulting in originations. A perfect correlation is "1", meaning that the same percentage of minority applications were originated as majority applications. Results greater than "1" indicate a higher incidence of minority mortgage applications resulted in the outcome and results less than "1" indicate a lower incidence of minority applications with the outcome. For origination rate comparisons, a high number is a positive comparison whereas for denials, "dropouts" (a combination of: withdrawn, incomplete and approved not accepted) and rate spread a number higher than "1" is an unfavorable ("negative") comparison. "Rate Spread" refers to mortgages whose rate met or exceeded the rate spread threshold as defined by the Regulation.
Report 100c - Gender (Reports 101-127 by purpose/lien/type)Fair Lending Variance Summary Report GDV Bank Recordsby Gender Focal Points:
Mortgage Type: AllMortgage Purpose: AllLien Position: All
Female Originations
Female Denials
Female Dropouts
Female Applications
Male Originations
Male Denials
Male Dropouts
Male Applications
GDV Bank 2012
Female Origination
Rate
Female Denial Rate
94 15 13122 77.05% 12.30%
95 43 26164
Female Dropout Rate
10.66%
Male Origination
Rate
57.93%
Male Denial Rate
26.22%
Male Dropout Rate
15.85%
Outcome Comparisons Origination Incidence Variance
Denial Incidence Variance
Dropout Incidence Variance
Female "Rate Spread"
Incidence
0.00%
Male "Rate Spread"
Incidence
2.11%
"Rate Spread" Incidence Variance
Female Rate Spread
Male Rate Spread
Units
0
2
1.33 0.47 0.67Positive Comparison
Positive Comparison
Positive Comparison
0.00Positive Comparison
Outcomes are compared based on the relative incidence of various outcomes. For example, the relative percentage of minority applications resulting in originations ("Origination Rate") is compared to the relative percentage of white mortgage applications resulting in originations. A perfect correlation is "1", meaning that the same percentage of minority applications were originated as majority applications. Results greater than "1" indicate a higher incidence of minority mortgage applications resulted in the outcome and results less than "1" indicate a lower incidence of minority applications with the outcome. For origination rate comparisons, a high number is a positive comparison whereas for denials, "dropouts" (a combination of: withdrawn, incomplete and approved not accepted) and rate spread a number higher than "1" is an unfavorable ("negative") comparison. "Rate Spread" refers to mortgages whose rate met or exceeded the rate spread threshold as defined by the Regulation.
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 1 Report 100c - Outcome Variance-All Records by Gender
Redlining Risk: Application Results in Assessment Area by Tract Income Class and Tract Number for GDV Bank Records
Report 130 - (Report 131 is similar, but includes Minority Tracts)
Focal Points: Mortgage Type: AllMortgage Purpose: AllLien Position: All
CountyName
CompleteTractNumberNumber of Applications
Originated Units
Denied Units
Dropout Units
Purchased Units
LowTract Income Class FAIR COUNTY
6 4 1 109001021400 0
2 2 0 009001021500 0
2 2 0 009001022200 0
2 1 1 009001043700 0
2 0 2 009001044100 0
1 0 0 1 0
15 9 4 2
09001044500
Totals for FAIR COUNTY
60.0% 26.7% 13.3%ORIGINATION, DENIAL AND DROPOUT RATES FOR Low INCOME CLASS TRACTS IN FAIR COUNTY
0
15 9 4 2
60.0% 26.7% 13.3%
TOTAL UNITS FOR Low INCOME CLASS TRACTS
ORIGINATION, DENIAL AND DROPOUT RATES FOR Low INCOME CLASS TRACTS
0
© 2012 GeoDataVision (203) 237‐1332 www.geodatavision.com Report 130‐ Redlining Analysis: Comparison of Origination, Denial and Dropout Rates by tract income class Page 1 of 7
CountyName
CompleteTractNumberNumber of Applications
Originated Units
Denied Units
Dropout Units
Purchased Units
ModerateTract Income Class FAIR COUNTY
2 1 0 109001020100 0
8 4 3 109001021300 0
5 1 2 209001021600 0
9 9 0 009001021802 0
12 8 3 109001021900 0
3 2 0 109001022000 0
10 8 1 109001022100 0
6 5 1 009001022300 0
4 3 0 109001043200 0
6 4 2 009001043400 0
3 2 1 009001043800 0
2 0 2 009001044000 0
1 0 1 009001044200 0
5 2 2 1 0
76 49 18 9
09001044400
Totals for FAIR COUNTY
64.5% 23.7% 11.8%ORIGINATION, DENIAL AND DROPOUT RATES FOR Moderate INCOME CLASS TRACTS IN FAIR COUNTY
0
76 49 18 9
64.5% 23.7% 11.8%
TOTAL UNITS FOR Moderate INCOME CLASS TRACTS
ORIGINATION, DENIAL AND DROPOUT RATES FOR Moderate INCOME CLASS TRACTS
0
© 2012 GeoDataVision (203) 237‐1332 www.geodatavision.com Report 130‐ Redlining Analysis: Comparison of Origination, Denial and Dropout Rates by tract income class Page 2 of 7
CountyName
CompleteTractNumberNumber of Applications
Originated Units
Denied Units
Dropout Units
Purchased Units
522 388 79 55
74.3% 15.1% 10.5%
TOTALS FOR GDV Bank
ORIGINATION, DENIAL AND DROPOUT RATES FOR GDV Bank
60.0% 26.7% 13.3% LOW‐INCOME CLASS TRACTS
MODERATE‐INCOME CLASS TRACTS 64.5%
MIDDLE‐INCOME CLASS TRACTS
UPPER‐INCOME CLASS TRACTS
74.6%
78.0%
23.7%
17.3%
10.2%
11.8%
8.1%
11.8%
ORIGINATION RATE DENIAL RATE DROPOUT RATE
COMPARISON OF ORIGINATION, DENIAL AND DROPOUT RATES BY TRACT INCOME CLASS
APPLICATIONS
15
76
185
246
22
© 2012 GeoDataVision (203) 237‐1332 www.geodatavision.com Report 130‐ Redlining Analysis: Comparison of Origination, Denial and Dropout Rates by tract income class Page 7 of 7
Report 132 - (Report 133 is similar, but includes applications from Minority Tracts)Review of GDV Bank Denied Application Records to Applicants from Low to Moderate Income Tracts in Assessment Area
Focal Points: Mortgage Type: AllMortgage Purpose: AllLien Position: All
CONNECTICUT
LoanAmount (thousands)
Income (thousands) LTV CLTV Credit Score Debt Ratio Lien Status
Combined Debt Ratio
Application Number
Denied Applications From Low Income TractsBorrower Income Class
Applicant Minority StatusTract
FAIR COUNTY
250 240 156.25% 156.25% 688 29.47%1 43.45%12-01-004624 Non-minority Upper044100
225 53 108.70% 108.70% 626 29.30%1 36.17%12-08-005149 Non-minority Low021400
108 66 36.00% 43.43% 719 28.45%1 63.17%12-09-005186 Minority Moderate044100
136 67 85.00% 97.67% 753 26.53%1 37.16%12-09-005229 Minority Moderate043700
4 Denied Applications in Low Income Tracts
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 2 Report 132 Denied Applications from Low to Moderate Income Tracts
Low and Moderate Income Tracts from GDV Bank Assessment Area with No Originations or Purchased Loans for GDV Bank but With Competitor Originations or Purchases
Report 134 - (Report 135 similar but includes Minority Tracts)
County Name
CompleteTractNumberCompetitors Total Units
Originated Units
Denied Units
Dropout Units
Fair Lending Reports for: GDV Bank
Purchased Units
LowTract Income Class FAIR COUNTY
139 59 30 3109001044100 19
61 24 14 16 7
200 83 44 47
09001044500
Totals for FAIR COUNTY 26
200 83 44 47TOTAL COMPETITOR UNITS FOR Low INCOME CLASS TRACTS 26
ModerateTract Income Class FAIR COUNTY
180 82 32 4009001044000 26
145 70 19 30 26
325 152 51 70
09001044200
Totals for FAIR COUNTY 52
325 152 51 70TOTAL COMPETITOR UNITS FOR Moderate INCOME CLASS TRACTS 52
© 2013 GeoDataVision (203) 237‐1332 www.geodatavision.com Report 134 ‐ Low to Moderate Income Tracts in Assessment Area Without Bank Originations or Purchased Loans Page 1 of 2
County Name
Competitors Total Units
Originated Units
Denied Units
Dropout Units
Fair Lending Reports for: GDV Bank
Purchased Units
525 235 95 117
CompleteTractNumber
Totals for Low and Moderate Tracts from GDV
Bank Assessment Area 78
© 2013 GeoDataVision (203) 237‐1332 www.geodatavision.com Report 134 ‐ Low to Moderate Income Tracts in Assessment Area Without Bank Originations or Purchased Loans Page 2 of 2
Housing Opportunities in Low and Moderate Income Tracts from GDV Bank Assessment Area with No Originations or Purchased Loans for GDV Bank
Report 136 - (Report 137 similar, but includes Minority Tracts)
County Name
CompleteTractNumberHousing Units
Occupied Units
Vacant Units
Owner Occupied Units
Renter Occupied Units
1 ‐ 4 Family Units
Multi‐ Family Units
Tract Income Class Low
FAIR COUNTY 1,77009001044100 1,491 279 416 1,075 559 1,211
1,27409001044500 1,141 133 391 750 685 589
3,044TOTALS FOR 2 TRACTS IN FAIR COUNTY 2,632 412 807 1,825 1,244 1,800
3,044TOTALS FOR 2 TRACTS IN LOW INCOME CLASS TRACTS 2,632 412 807 1,825 1,244 1,800
Tract Income Class Moderate
FAIR COUNTY 2,70809001044000 2,505 203 891 1,614 1,589 1,119
1,95509001044200 1,659 296 646 1,013 1,510 445
4,663TOTALS FOR 2 TRACTS IN FAIR COUNTY 4,164 499 1,537 2,627 3,099 1,564
4,663TOTALS FOR 2 TRACTS IN MODERATE INCOME CLASS TRACTS 4,164 499 1,537 2,627 3,099 1,564
7,707Totals for 4 Low and Moderate Income Tracts from GDV Bank Assessment Area
6,796 911 2,344 4,452 4,343 3,364
© 2012 GeoDataVision (203) 237‐1332 www.geodatavision.com Report 136 ‐ Low to Moderate Income Tracts in Assessment Area Without Bank Originations or Purchased Loans Page 1 of 1
Report 138 - Minority Rate Spread Units (Report 139 similar, but for Female Borrowers)
Listing of GDV Bank Minority Rate Spread Units for Review
LoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIOLien Status COMB.DEBT RATIORate SpreadMinority Application NumberMinority Classification
NO QUALIFYING RECORDS FOR THIS REPORT
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 1 Report 138 - Minority Rate Spread Units
Fair Lending Analysis of Process Times for GDV Bank Records by Minority Class
Report 140 - (Report 141 is similar but compares processing times by gender)
Action Type Number of Units Average Process Time in Days
Originated
Asian 8119
Black 859
Hispanic 6720
MultiRacial 502
White 70381
431Total Originated
Appl approved not accepted
Asian 1361
Hispanic 1591
White 1246
8Total Appl approved not accepted
Denied
Asian 235
Black 206
Hawaiian Islander/Pacific Islander 31
Hispanic 2510
White 2582
104Total Denied
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 2Report 140 - Process Times by Minority Class
Action Type Number of Units Average Process Time in Days
Appl withdrawn
Asian 146
Black 152
Hispanic 134
White 2530
42Total Appl withdrawn
File closed incomplete
Black 671
White 459
10Total File closed incomplete
Purchase
Asian 1
Hispanic 1
White 23
25Total Purchase
Preapproval approved not accepted
Hispanic 861
White 693
4
624
Total Preapproval approved not accepted
Total Applications for GDV Bank
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 2 of 2Report 140 - Process Times by Minority Class
Fair Lending Comparison of Actions Taken by GDV Bank to Competitor Actions Within the Assessment Area
Report 142
Bank AppsAction Type Bank % Market % DifferenceCompetitor Apps
Originated 388 74.33% 66.66% 7.67%14,999
Appl approved not accepted 8 1.53% 4.89% ‐3.36%1,101
Denied 79 15.13% 14.60% 0.53%3,286
Appl withdrawn 38 7.28% 9.47% ‐2.19%2,130
File closed incomplete 9 1.72% 4.38% ‐2.66%986
522Total Applications for GDV Bank
100.00% 100.00%22,502
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 1Report 142 - Comparison of Actions Taken
This report reflects the activity from the 2012 data provided by GDV Bank from within their assessment area compared to their competitors' market data from 2012 within GDV Bank's 2012 assessment area. This analysis excludes purchase and preapproval activity.
Summary of Activity in Assessment Area for GDV Bank Records by Minority Class
Report 143
Population % in Assessment Area
% of Applications taken by Bank
% of Loans Originated by Bank
Minority Classification
American Indian/Alaskan Native 0.00%0.18% 0.00%
Asian 5.18%6.38% 4.41%
Black 3.01%8.46% 2.09%
Hawaiian/Pacific Islander 0.17%0.04% 0.00%
Hispanic 6.01%16.20% 4.64%
Multi‐Racial 0.33%0.69% 0.46%
White 85.31%68.05% 88.40%
100.00%100.00% 100.00%
Application and origination calculations are based only on those applications where minority information was provided.
Applicants who are both Hispanic and members of a minority race (such as Black, Asian, etc.) are counted only once for purposes of this demographic report. If a person is both Hispanic and a racial minority they are counted as Hispanic and not counted as a racial minority. Therefore, there may be some under‐counting of the racial categories because, for example, Black Hispanics (or other racial minority) are counted only as Hispanics (and not as Blacks) in the above demographic data.
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 1Report 143 - Summary of Activity by Minority Class
Summary of Activity in Assessment Area for GDV Bank and Competitors Records by Minority Class
Report 144
% of Applications in Assessment Area
% of Applications in Assesmsent Area
% of Originations in Assessment Area
Minority Classification % of Originations in Assessment Area
Competitor Activity GDV Bank
American Indian/Alaskan Native 0.00%0.08% 0.00%0.06%
Asian 4.96%6.01% 3.61%6.49%
Black 2.02%2.03% 1.80%1.69%
Hawaiian/Pacific Islander 0.00%0.18% 0.00%0.19%
Hispanic 5.70%4.63% 4.64%4.46%
Multi‐Racial 0.18%0.27% 0.26%0.27%
Not Provided or NA 7.17%21.22% 7.47%13.17%
White 79.96%65.57% 82.22%73.67%
Application and origination calculations are based only on those applications where minority information was provided.
Applicants who are both Hispanic and members of a minority race (such as Black, Asian, etc.) are counted only once for purposes of this demographic report. If a person is both Hispanic and a racial minority they are counted as Hispanic and not counted as a racial minority. Therefore, there may be some under‐counting of the racial categories because, for example, Black Hispanics (or other racial minority) are counted only as Hispanics (and not as Blacks) in the above demographic data.
100.00%100.00% 100.00%100.00%
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 1Report 144 - Summary of Competitor Activity by Minority Class
Fair Lending Analysis of APRs for GDV Bank Recordsby Minority Class
Report 150 (Report 151 similar but for gender)
For Terms of Less than 20 Years Number of Units Average APR % of White APR
Term Category
Home Purchase ‐ First LienAsian 3.7215 100.00%Black 3.862 104.00%Hispanic 4.262 115.00%White 3.7171 100.00%
90Total Home Purchase ‐ First Lien
90Total Home Purchase
Home Improvement ‐ First LienBlack 3.692 99.00%White 3.7325 100.00%
27Total Home Improvement ‐ First Lien
27Total Home Improvement
Refinancing ‐ First LienAsian 3.2923 95.00%Black 3.494 101.00%Hispanic 3.794 110.00%White 3.46220 100.00%
251Total Refinancing ‐ First Lien
251Total Refinancing
368Total for Less than 20 Years
For Terms of 20 Years or More Number of Units Average APR % of White APR
Term Category
© 2013 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 3Report 150 - Comparisons of APRProcess Times by Minority Class
Review of GDV Bank Records to Identify Minority Applicants Denied for Credit With Credit Scores Greater Than or Equal to Approved Non-Minority Borrowers
Report includes all mortgage types with comparisons sorted by
mortgage type
Report 200a - (Report 200b similar, but makes comparisons for gender)
Loan Type - Conventional
Denied Minority ApplicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
Black Non-Hispanic12-10-005235 350 139 70.00% 70.00% 649 25.28%1 55.26%
Black Non-Hispanic12-04-004827 420 187 83.17% 83.17% 632 22.95%1 43.04%
2 Denied Minority Applications
Originated Non-minority applicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
White Non-Hispanic11-12-004545 350 229 41.18% 52.21% 629 26.70%1 39.01%
White Non-Hispanic11-12-004603 160 49 61.54% 61.54% 635 40.80%1 44.99%
White Non-Hispanic12-06-004946 95 31 48.72% 48.72% 641 33.96%1 34.35%
White Non-Hispanic12-05-004879 301 142 50.17% 50.17% 643 23.16%1 36.41%
White Non-Hispanic11-11-004520 684 234 80.00% 80.00% 643 26.37%1 39.71%
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 2 Report 200a - Review of applications by credit score criteria
Report 200c - (Report 200d similar, but makes comparisons for gender)GDV Bank Records With Credit Scores Out of Range* and Not Included Report in 200a Comparisons
Report includes out of range records sorted by mortgage type
Loan Type - Conventional
Originated Non-minority applicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
White Non-Hispanic12-06-004941 185 70 0.00% 0.00% 0 0.00%1 0.00%
1 Originated Non-minority applications
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 1 Report 200c - Records with out of range credit scores
* Out of Range is defined as any credit score less than 300 or greater than 900 or missing
Review of GDV Bank Records to Identify Minority Applicants Denied for Income With Debt Ratios Less than or Equal to Approved Non-Minority Borrowers
Report includes all mortgage types with comparisons sorted by
mortgage type
Report 201a - (Report 201b similar, but makes comparisons for gender)
Loan Type - Conventional
Denied Minority ApplicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
Black Non-Hispanic12-04-004827 420 187 83.17% 83.17% 632 22.95%1 43.04%
White Hispanic12-07-005071 16 59 4.00% 83.99% 803 43.86%2 49.59%
Asian Non-Hispanic12-09-005178 860 242 78.18% 78.18% 777 32.14%1 51.44%
Black Non-Hispanic12-02-004669 100 80 43.48% 43.48% 722 7.48%1 51.47%
Asian Non-Hispanic12-11-005302 250 84 34.29% 34.29% 725 32.61%1 51.77%
Black Non-Hispanic12-10-005235 350 139 70.00% 70.00% 649 25.28%1 55.26%
White Hispanic12-07-005070 228 128 80.00% 80.00% 788 17.44%1 60.07%
White Hispanic12-11-005330 330 52 100.00% 100.00% 599 58.61%1 60.36%
White Hispanic12-09-005186 108 66 36.00% 43.43% 719 28.45%1 63.17%
9 Denied Minority Applications
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 9 Report 201a - Review of applications by debt ratio criteria
Review of GDV Bank Records to Identify Minority Applicants Denied for Income With Debt Ratios Less than or Equal to Approved Non-Minority Borrowers
Report includes all mortgage types with comparisons sorted by
mortgage type
Report 201a - Last page in the series.
Loan Type - Conventional
Originated Non-minority applicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
White Non-Hispanic12-06-004936 250 63 45.45% 53.03% 764 37.53%1 43.36%
White Non-Hispanic12-09-005230 218 84 33.54% 37.95% 713 32.43%1 43.32%
White Non-Hispanic12-07-005030 1027 304 56.27% 56.27% 660 32.12%1 43.22%
White Non-Hispanic12-03-004738 328 102 80.00% 102.07% 674 33.25%1 43.19%
White Non-Hispanic12-09-005194 972 356 80.00% 80.00% 732 20.39%1 43.10%
75 Originated Non-minority applications
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 9 of 9 Report 201a - Review of applications by debt ratio criteria
Report 201c - (Report 201d similar, but makes comparisons for gender)GDV Bank Records With Debt Ratios Out of Range* and Not Included Report in 201a Comparisons
Report includes out of range records sorted by mortgage type
Loan Type - Conventional
Denied Minority ApplicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
Black Hispanic12-02-004689 27 95 90.00% 90.00% 584 9.53%1 753.34%
1 Denied Minority Applications
Originated Non-minority applicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
White Non-Hispanic12-02-004673 212 24 39.26% 48.29% 804 106.95%1 164.89%
White Non-Hispanic12-06-004941 185 70 0.00% 0.00% 0 0.00%1 0.00%
White Non-Hispanic12-10-005259 275 1 74.53% 74.53% 717 0.00%1 0.00%
3 Originated Non-minority applications
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 1 Report 201c - Records with out of range debt ratios
* Out of Range is defined as any debt ratio less than 2 or greater than 150 or missing
Review of GDV Bank Records to Identify Minority Applicants Denied for Collateral With Loan to Value Ratios Less Than or Equal to Approved Non-Minority Borrowers
Report includes all mortgage types with comparisons sorted by
mortgage type
Report 202a - (Report 202b similar, but makes comparisons for gender)
Loan Type - Conventional
Denied Minority ApplicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
Black Non-Hispanic12-02-004669 100 80 43.48% 43.48% 722 7.48%1 51.47%
Asian Non-Hispanic12-01-004612 130 150 66.67% 66.67% 800 23.03%1 34.13%
White Hispanic12-02-004717 280 72 67.47% 67.47% 739 32.26%1 39.00%
Asian Non-Hispanic12-09-005178 860 242 78.18% 78.18% 777 32.14%1 51.44%
Black Non-Hispanic12-04-004827 420 187 83.17% 83.17% 632 22.95%1 43.04%
Asian Non-Hispanic12-06-004991 1000 531 84.75% 84.75% 804 16.28%1 18.26%
Black Non-Hispanic12-03-004759 228 97 87.69% 87.69% 672 31.73%1 40.36%
HIPI Non-Hispanic12-01-004621 284 61 93.42% 93.42% 670 35.12%1 58.59%
White Hispanic12-09-005229 136 67 85.00% 97.67% 753 26.53%1 37.16%
White Hispanic12-11-005330 330 52 100.00% 100.00% 599 58.61%1 60.36%
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 29 Report 202a - Review of applications by loan to value criteria
Review of GDV Bank Records to Identify Minority Applicants Denied for Collateral With Loan Value Ratios Less Than or Equal to Approved Non-Minority Borrowers
Report includes all mortgage types with comparisons sorted by
mortgage type
Report 202a - (Last page with total of records in the category)
Loan Type - Conventional
Originated Non-minority applicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
White Non-Hispanic12-08-005106 160 144 18.39% 43.68% 721 39.72%1 39.72%
269 Originated Non-minority applications
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 29 of 29 Report 202a - Review of applications by loan to value criteria
Report 202c - (Report 202d similar, but makes comparisons for gender)GDV Bank Records With Loan to Value Ratios Out of Range* and Not Included Report in 202a Comparisons
Report includes out of range records sorted by mortgage type
Loan Type - Conventional
Denied Minority ApplicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
White Hispanic12-03-004796 160 95 91.43% 158.73% 697 32.81%1 37.28%
1 Denied Minority Applications
Originated Non-minority applicationsLoanAmount (thousands)
Income (thousands)
LTV CLTV CREDIT SCORE DEBT RATIO COMB.DEBT RATIO
Loan Minority Class Lien StatusApplication Number
White Non-Hispanic12-04-004836 183 75 154.66% 154.66% 751 26.37%1 40.40%
White Non-Hispanic12-06-004941 185 70 0.00% 0.00% 0 0.00%1 0.00%
2 Originated Non-minority applications
© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com Page 1 of 1 Report 202c - Records with out of range loan to value ratios
* Out of Range is defined as any loan to value ratio less than 2 or greater than 150 or missing
Assessment Area TableThe following tracts comprise the assessment area used in selected reports
GDV Bank
County MSA- Complete Tract Number
Tract Inc Class
Minority Tract*
14860-09001010101 Upper No
14860-09001010102 Upper No
14860-09001010201 Upper No
14860-09001010202 Upper No
14860-09001010300 Upper No
14860-09001010400 Middle No
14860-09001010500 Middle No
14860-09001010600 Upper No
14860-09001010700 Middle No
14860-09001010800 Upper No
14860-09001010900 Upper No
14860-09001011000 Upper No
14860-09001011100 Upper No
14860-09001011200 Upper No
14860-09001011300 Middle No
14860-09001020100 Moderate Yes
14860-09001020200 Upper No
14860-09001020300 Upper No
14860-09001020400 Upper No
14860-09001020500 Upper No
14860-09001020600 Middle No
14860-09001020700 Middle No
14860-09001020800 Upper No
14860-09001020900 Middle No
14860-09001021000 Middle No
14860-09001021100 Middle No
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY 14860-09001021200 Middle No
Page 1 of 3© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com
*Minority Tracts defined as tracts with a minority population percent of 50% or greater
County MSA- Complete Tract Number
Tract Inc Class
Minority Tract*
14860-09001021300 Moderate Yes
14860-09001021400 Low Yes
14860-09001021500 Low Yes
14860-09001021600 Moderate Yes
14860-09001021700 Middle Yes
14860-09001021801 Middle No
14860-09001021802 Moderate Yes
14860-09001021900 Moderate No
14860-09001022000 Moderate Yes
14860-09001022100 Moderate Yes
14860-09001022200 Low Yes
14860-09001022300 Moderate Yes
14860-09001022400 Upper No
14860-09001030100 Upper No
14860-09001030200 Upper No
14860-09001030300 Upper No
14860-09001030400 Upper No
14860-09001030500 Upper No
14860-09001035100 Upper No
14860-09001035200 Upper No
14860-09001035300 Upper No
14860-09001035400 Upper No
14860-09001042500 Middle No
14860-09001042600 Middle No
14860-09001042700 Middle No
14860-09001042800 Middle No
14860-09001042900 Upper No
14860-09001043000 Middle No
14860-09001043100 Middle No
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY 14860-09001043200 Moderate Yes
Page 2 of 3© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com
*Minority Tracts defined as tracts with a minority population percent of 50% or greater
County MSA- Complete Tract Number
Tract Inc Class
Minority Tract*
14860-09001043300 Middle No
14860-09001043400 Moderate Yes
14860-09001043500 Middle No
14860-09001043600 Middle No
14860-09001043700 Low Yes
14860-09001043800 Moderate Yes
14860-09001043900 Middle No
14860-09001044000 Moderate Yes
14860-09001044100 Low Yes
14860-09001044200 Moderate Yes
14860-09001044300 Middle No
14860-09001044400 Moderate Yes
14860-09001044500 Low Yes
14860-09001044600 Upper No
14860-09001045101 Upper No
14860-09001045102 Upper No
14860-09001045200 Upper No
14860-09001045300 Upper No
14860-09001045400 Upper No
14860-09001050100 Upper No
14860-09001050200 Upper No
14860-09001050300 Upper No
14860-09001050400 Upper No
14860-09001050500 Upper No
14860-09001050600 Upper No
14860-09001055100 Upper No
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY
FAIR COUNTY 14860-09001055200 Upper No
84 tracts
Page 3 of 3© 2012 GeoDataVision (203) 237-1332 www.geodatavision.com
*Minority Tracts defined as tracts with a minority population percent of 50% or greater