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May 28, 2009

Comments

Fred Rivera

The FFIEC's updated guidance on HMDA could not be more timely. As the number rejected mortgage loan applicants increase from tightening credit markets and increased underwriting scrutiny, regulators and plaintiffs' attorneys will return to the days of utilizing HMDA data to evaluate potential discriminatory lending patterns as a basis to initiate litigation. Lenders are wise to ensure their HMDA data is accurate, and to proactively review for trends.

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