Peer

To benchmark CRA and HMDA lending against peers, pick a group of lenders that compete in the same markets with a similar size and product mix, pull their public HMDA and CRA data for the same year and the same geography, and compare market share, lending by tract income level, denial rates and pricing. The comparison only holds up if the peer group does. Your own numbers mean little on their own. Say you hold a 6% share of home purchase originations in moderate-income tracts. That could be strong or weak, and nobody can tell which until it sits next to what lenders like you did in the same tracts in the same year. Examiners make that comparison as a matter of course, so it makes sense to make it first. This guide covers where the data comes from, how to build a peer group that will…

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