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ERS Group economists have appeared before the Department of Justice, the Federal Reserve Bank, and other regulatory agencies as experts on issues involving credit decisions.
While in the past regulatory agencies have scrutinized lending and credit practices from a financial and fiduciary perspective, for over a decade they have increased efforts to investigate financial institutions' lending and credit decisions from an equal opportunity perspective. ERS Group statistical models reflect actual lending practices, borrower populations, and market forces. We analyze allegations of discrimination based on age, race, ethnicity, gender, and low-to-moderate income buyer status, as well as investigate redlining in the loan application process, and loan or credit terms -- including note rate, the annual percentage rate (APR), broker points, lender points, assignment of risk calculations, and differences in foreclosure rates by protected group status.
We provide pre-audit analyses of HMDA and other data to institutions interested in anticipating the results of an audit of its lending practices. ERS Group's analyses identify potential problems for further review or more complex statistical analysis. Ready access to national Bureau of Census data and publicly available loan data in combination with our previous experience ensures that the conclusions we reach are statistically sound and reliable.
Our capabilities include:
- Objectively evaluating the neutrality of past lending and credit decisions.
- Clearly presenting analyses to regulatory agencies and courts.
- Appropriately determining alleged economic damages by class of loan or on a loan-by-loan basis.
- Periodically monitoring credit decisions in order to detect patterns that have an adverse impact on protected demographic groups.
We work with defendants and plaintiffs from many types of financial institutions, including Brokerage Firms, Banks, Mortgage Lenders, and other credit providers. |
