Skip to main content
OCC Flag

An official website of the United States government

July 2009

Does Multiple Jeopardy Exist in Mortgage Markets? (WP 2009-3)

This publication is part of:

Collection: Economics Working Papers Archive


Under the Home Mortgage Disclosure Act (HMDA), lenders are required to gather and report information on applicants' and co-applicants' ethnicity, race, and gender. These three characteristics are used to define protected class and control groups used for fair lending analyses. Typically, each characteristic is analyzed in isolation. This study explores whether treatment in mortgage markets is affected by belonging to multiple minority groups.

Using HMDA data from 2005 for 22 national banks, along with data from three fair lending examinations the Office of the Comptroller of the Currency (OCC) has recently conducted, we analyze whether membership of multiple minority groups is beneficial, harmful, or of no consequence to treatment in mortgage markets. Overall, there are a number of statistically and economically significant results supporting each of these effects. The primary conclusion, therefore, is that interaction effects are important and should be fully explored during fair lending analyses.


Jason Dietrich