A Comparison of Unexplained Racial Disparities in Bank-Level and Market-Level Models of Mortgage Lending.

Statistical models of mortgage lending have been used by both academics and regulators to assess the importance of racial discrimination in lending decisions. Models estimated by bank regulators are specified at a bank level, allowing regulators to focus on possible disparate treatment discrimination against minorities. In contrast, the academic literature has tended to estimate models combining data across many banks. We argue that the market-level approach uses a mis-specified model whose estimates do not clearly measure any well-defined concept of discrimination. Using data from eight banks, we find important differences between bank-level and market-level models, with market-level models producing larger estimated racial effects than bank-level models. [ABSTRACT FROM AUTHOR]