Hugh asked:
What do you think outcome of the agencies' investigations and citations will be? Is it simply more access to loans in underprivileged areas? Are there no negative consequences?
Here is what I think will likely happen given a set of logical assertions and conclusions.
1) These regulatory and oversight agencies will look into the lending trends and practices of financial institutions in these areas.
2) I would expect that the agencies will start by looking at trends and statistics related to those approved, per-capita, or per applicant for said areas and then compare and contrast those statistics with some other sample averages, possibly nationwide averages. If the area's trends are aligned with the expected samples, then I would expect the agencies will stop their analysis then and there.
3) However, if the comparitive analysis described above display possible anomolies then I expect the agencies will dig deeper and review actual applications. If it comes to that then upon their review they either find wrong-doing, or they won't. When I say "wrong-doing" they will find evidence that people that should have been granted loans were denied. Or, they will find no evidence of such wrong doing.
4) It is very possible (in my opinion) that no wrong-doing will be found. In other words, I expect that IF it is the case that there seems to be lower rates of lending going on in these areas it will probably be shown to be caused by a number of factors, including but not limited to:
a. those applying aren't qualified
b. there are fewer, on average, per-capita applying for loans (probably because they know they won't qualify)
c. these areas have a majority of renters and rental units, and far fewer actual homes for sale and far fewer people who want to be homeowners.
So, I expect that these agencies will do their job. I suspect they won't find any significant wrong-doing, and find that the lenders are acting in good faith, and because of that there will be no "call" by the agencies for the lenders to change anything. Thus, things will proceed as it is currently.
I don't agree with the premise that there are a lot of people that are being denied access to loans simply because of where they live. I suspect that more than likely where they live is an indicator of other things, and some of those things are the reasons that they were declined access to loans.
People would like to claim they are the subject of discrimination based on where they live, or the color of their skin, or the clothes they wear, or how they speak, or their fitness level (yeah, fat people are discriminated against)...whatever. However, the way I see it is that the unfair "reality" (in my mind) is that more often than not the person that is doing the discriminating is seeing past those superficial things and grasping at root cause reasons, and those reasons and factors are the reasons for the dismissing.
Like the lottery ticket winner example, the same decisions and factors that lead someone to live in a ghetto area (okay, that's what I called it), are the same factors that will work against them in getting a loan. Lower education, lower earning potential, poor or no credit, little or no cash on-hand, these things are often the case for people living in these areas. It is the rare exception that an educated, well-off person lives in these areas. Does that mean a lender should be allowed to deny loans to all that live in such areas, without looking at qualifications? Of course not. But by the same token, lenders that do deny shouldn't be assumed to be denying just because of where the applicants live.
TJR