ABSTRACT
This chapter describes the Department of Housing and Urban Development (HUD) secretary-initiated enforcement program and the process for targeting a lending discrimination investigation. The secretary of HUD also was authorized to initiate investigations to determine whether a housing discrimination complaint should be filed and to file a complaint on his or her own initiative. The chapter explains the utility of Home Mortgage Disclosure Act (HMDA) data for targeting purposes, even though the data cannot be used to prove a prima facie case of discrimination. It focuses on using HMDA and census tract data to identify a lender’s policies, procedures, or practices that suggest possible discrimination. The targeting process involved four stages, beginning with a general examination of the lender’s operation and concluding with the identification of individual application files for review. The available information was streamlined by comparing the approval/denial rates of each categorical variable in the HMDA database.
