HMDA Analysis · 2021–2023

Fair Lending Analysis

Two-stage logistic regression on 4.49 million HMDA mortgage applications across ten institutions. Black-White adjusted approval odds ratios after controlling for income, DTI, loan amount, and purpose.

0.539
Industry median Black OR
across ten institutions
0.456–0.713
Peer range
largest to smallest gap
≈ 1.000
Hispanic OR (median)
largely at parity
19.4 pp
Raw approval gap
industry average
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Odds ratios from two-stage MLE logistic regression (statsmodels). Controls: log income, log loan amount, DTI midpoint, loan purpose indicators. HMDA does not include credit scores; estimates are upper bounds on the true credit-score-adjusted disparity. All gaps significant at p < 0.001.