Comptroller of the Currency, Administrator of National Banks Ensuring a Safe and Sound National Banking System for all Americans
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Publications:
Under-specified Models and Detection of Discrimination in Mortgage Lending

by Jason Dietrich

Abstract

Most empirical studies of discrimination in mortgage lending can be criticized for omitted variable bias. With access to data and policy guidelines typically unavailable to researchers, the OCC is in a unique position to assess the importance of omitted variables on fair lending models. This study examines how variables available to the OCC, but often unavailable to researchers, affect estimates from statistical models and identification of outliers for manual review.

The results show that omitted variables have an important impact on both the estimate of the effect of race and on the identification of outliers for review. Further, there appears to be no consistent patterns to the direction of these impacts. This suggests that it is inappropriate to make generalizations about the potential direction of bias based on assumptions about the correlations between omitted variables and race.

Disclaimer

Any whole or partial reproduction of material in this paper should include the following citation: Jason Dietrich, "Under-specified Models and Detection of Discrimination in Mortgage Lending," Office of the Comptroller of the Currency, E&PA Working Paper 2003-2, March 2003.

Availability

The paper is available for viewing in Adobe's PDF format. The PDF viewer is available for download free from Adobe in versions for different platforms.

The complete paper is available in hard copy from the OCC's Communications Division. If you would like to receive a copy of a paper through the U.S. Postal Service:

  • Write to the Communications Division, Mail Stop 3-3, Office of the Comptroller of the Currency, Washington, DC 20219, or
  • Send an e-mail request to the Communications Division at foia-pa@occ.treas.gov.
Be sure to identify the paper(s) you want and to include your complete mailing address, including ZIP code.

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The Office of the Comptroller of the Currency was created by Congress to charter national banks, to oversee a nationwide system of banking institutions, and to assure that national banks are safe and sound, competitive and profitable, and capable of serving in the best possible manner the banking needs of their customers.

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