FL Wiz Training Manual 9-08
Fair Lending Wiz Training GuideDate: 9/2008 Wolters Kluwer Financial ServicesWiz is registered in the U.S. Patent and Trademark Office.
Fair Lending Wiz Training GuideTable of ContentsChapter 1 – Importing. 7Overview . 8Exercise 1: Importing a File Into FL Wiz . 9Exercise 2: Updating an Existing File . 21Chapter 2 – Editing Data for Fair Lending . 29Overview . 30Exercise 1: Reviewing Data . 31Exercise 2: Replacing Zeroes with “Nulls” . 41Exercise 3: Using Modify Codes to Allow User Defined Fields to be Used. 45Chapter 3 – Custom Tables. 51Overview . 52Exercise 1: Obtaining a Distribution by Loan Product. 53Exercise 2: Calculating the Average APR by Loan Product . 61Chapter 4 – File Management . 69Overview . 70Exercise 1: Copying a File. 71Exercise 2: Copy with Filter . 73Exercise 3: Modifying a File’s Structure. 78Exercise 4: Adding Values to a New Field . 81Exercise 5: Adding/Modifying New Codes . 86Exercise 6: Transferring/Installing a File . 89Chapter 5 – Introduction to Statistics. 93Overview . 94Chapter 6 – Fair Lending Examination Procedures . 99Examination Scope Guidelines .101Understanding Credit Operations.102Evaluating the Potential for Discriminatory Conduct .104Compliance Program Discrimination Risk Factors.106Identify Residential Lending Risk Factors.107Overt Risk Factors .109Underwriting Risk Factors .109Pricing Risk Factors .109Steering Risk Factors.110Redlining Risk Factors.110Marketing Risk Factors.112
Table of ContentsIdentify Consumer Lending Risk Factors.113Identify Commercial Lending Risk Factors.114Chapter 7 – Data Integrity and Scoping .117Overview .118Exercise 1: Generating Reports with Filters.119Summary Report – Action Taken and Standard Summary Report without Filters.120Summary Reports with Filters .125Exercise 2: Generating Data Quality Reports.127Understanding Data Quality Reports .130Applying a Filter to Data Quality Reports.132Exercise 3: Generating and Understanding Difference of Means Reports .138Analyzing the APR .143Analyzing the Credit Score.146Analyzing Denied Credits using the Difference of Means Reports.147Exercise 4: Generating Risk Factor Reports .149Disparities in Denial Rates (Underwriting).153Disparities in Processing Times (Underwriting) .156Credit Score Overrides (Underwriting) .159Proportion of FHA versus Conventional Mortgages (Steering) .164Redlining Reports .166Exercise 5: HMDA Scoping Reports .168Differences in Average Rate Spread .171Pricing Disparity Summary .173Risk Score by Geography .175Chapter 8 – Introduction to Decisioning Regression.179Overview of Logistic Regression .180Specific Examples of Logistic Regression .181Chapter 9 – Decisioning Regression .183Overview – Factors to Use in Regression Models .184Exercise 1: Creating a Decisioning Regression Model .185Exercise 2: Analyzing Decisioning Regression Results .191Advanced Statistics.195Race .196Denied and Review – Details .197Reviewing the Applicant Detail Record.199Visual Analysis .201Exercise 3: Changing the % Cutoff .208Exercise 4: Exporting and Printing Lists of Applicants .211Chapter 10 – Hands-On Exercise Decisioning Regression.219Copyright Wolters Kluwer Financial Services 2008TOC-2Rev. 09-08
Table of ContentsChapter 11 – Introduction to Pricing Regression.223Overview of Linear Regression.224Chapter 12 – Mortgage Pricing Regression .225Overview .226Exercise 1: Creating a Pricing Regression Model for a Mortgage File .227Exercise 2: Analyzing the Mortgage Pricing Regression Results.233Result of “Above Predicted” .236Analyzing the Results Using Visual Analysis.240Chapter 13 – Hands-On Exercise – Pricing Regression.245Chapter 14 – Best Practices for Regression .249Chapter 15 – Introduction to Comparative File Review.255Overview .256Decisioning Comparison Classifications .258Chapter 16 – Decisioning Comparison by Race/Ethnicity .259Exercise 1: Creating a Comparative File Review Model.260Match Factors versus Tolerance Factors .262Exercise 2: Analyzing the File Comparison Results.268Using the Results of the Decisioning Regression Model .269Visual Analysis .274Exercise 3: Exporting the Side-by-Side Comparison to Excel .278Preparing the Spreadsheet .280Sorting Left to Right in Excel.283Chapter 17 – Hands-On Exercise Decisioning Comparison.285Chapter 18 – Pricing Comparison.289Exercise 1: Creating a Pricing Comparison Model.290Exercise 2: Setting the Model to be a “Race” Model.297Exercise 3: Analyzing the File Comparison Results.301Chapter 19 – Hands-On Exercise Pricing Comparison .309Chapter 20 – Best Practices for Comparative File Review .313Chapter 21 – Focal Point Report.319Overview .320Exercise 1: Creating the Focal Point Report for the Overall LAR.321Exercise 2: Interpreting the Focal Point Report.329Copyright Wolters Kluwer Financial Services 2008TOC-3Rev. 09-08
Table of ContentsBlank PageCopyright Wolters Kluwer Financial Services 2008TOC-4Rev. 09-08
ImportingChapter 1ImportingUpon completion of this lesson you will be able to:XImport a loan file.XAdd records from one file into an existing file using the Updatefeature.7
Fair Lending Wiz Training GuideOverviewIn order to have the most robust Fair Lending analysis, having access to relevant fields contained inyour LOS (loan origination system) will enable you to perform a comprehensive analysis. But sometimes those fields are not captured in your LOS. How can you include them in your file once you’vereceived an extract containing the basic fields?The following exercise will take you through the steps which will enable you to add, or update, datainto an existing CRA/FL Wiz file. But before we can add information to an existing file, we mustfirst import a file that has been generated from your LOS. When reviewing the extract, you noticethat you will need to include fair lending fields to perform an in-depth fair lending analysis, fieldssuch as Credit Score, LTV, and Back End Ratio, to name a few.Your MIS group has provided you with an extract containing the standard HMDA fields, and hasalso provided you with another file that includes various fair lending fields. You need to import theextract file, then add the additional fields to your extract file.8
ImportingExercise 1: Importing a File Into FL WizThere are three ways to import a file: (1) Importing a New File, (2)Updating an Existing File, and (3) Appending to an Existing File.Importing a New File brings new information into CRA/FL Wiz.Importing using the Update a File feature makes use of an existingCRA/FL Wiz file but allows a user to change and/or add new information into that file. Importing data using the Append a File feature allowsthe user to only add new information into an existing CRA/FL Wiz file.Before you can add data into an existing file, you must first import a newfile. When you bring in this file you will need to create ‘place holders’, orempty fields that will accept the information that needs to be added toyour extract. To import a file, follow these steps:1. Select the Main tab and click theImport Wizard button.9
Fair Lending Wiz Training Guide2. Select New Format. Hit theNext button found at thebottom of the screen.3. Select Text as the SourceData Type.4. To locate the file to import,click the ellipsis button tonavigate to the folder andthen the source file (FLMortgage File.csv). ClickNext.5. The Source File FormatSelection screen allows youto set how your file is structured.10
Importing6. Click the Row Delimiterdrop-down button and selectCarriage Return.7. Click the Text Qualifierdrop-down button. SelectNone.8. Check the box next to FirstRow Has Column Names.By using this feature, thesoftware will automaticallymatch or “map” the fieldsfound in your LOS to thefields found in CRA/FL Wiz.Click Next.9. The software displays theText File Column Delimiter Selection screen whenthe source file is a delimited text file. You use thisscreen to select the type ofdelimiter used to separatefields in the source file.Select Comma. ClickNext.11
Fair Lending Wiz Training Guide10. The Target File Selectionscreen provides you with thedifferent file types, alongwith the ability to name yourfile. From the drop-downbox, select Mortgage 2004.Note: Use Mortgage 2004 forfiles created in 2004 and beyond.This file type incorporateschanges made to the Regulationsstarting with 2004 submissionfiles.11. Under the New File option,type Mortgage YTD. ClickNext.Note:Which of these 3 options to usedepends on your source file.“New file” would be used for thefirst month, or quarter, or anentire year. “Update” would beused to update an existing file.“Append” would be used toADD a new quarter onto the previous quarter’s data. KNOWyour file’s contents.12. You use the Census YearSelection screen to indicate whether you want toimport a file with 1990 or2000 census boundaries.Import a loan file using2000 census tract boundaries for action dates 2003. Click Next.12
Importing13. Select the File Will beGeocoded in Wiz System check box if you wantto geocode the file inCRA/FL Wiz. ClickNext.Note:File must contain values in thefiles MSA, State, County, andCensustrac if you are NOT usingthe Wiz geocoder.To be geocoded within the Wiz,the file must contain Address,City, State abrv, and Zip.14. Click the Auto-MapRemaining SourceColumns link. This linkautomatically maps thefields in your Source column and lists the fields inthe Target column only ifthe source field matchesthe CRA/FL Wiz fieldname. If the softwarecould not match a field,the corresponding sourcefield displays none .You would then have to manually map the source field.Look at the Data Preview for the Loan Amount field. The Loan Amount is displayed in wholedollars. However, the format for submission (and the software) requires the loan amount to bedisplayed in thousands.You can add a replace command -- a command that will change the value in a specific field inthe source file -- while you are importing records into CRA/FL Wiz. This is helpful to manip13
Fair Lending Wiz Training Guideulate data into a format required for submission and analysis purposes.Example:Source FileLoan Amount130000(Source 1000)130You will add a replace command to the import format so Loan Amount will be automaticallydivided by 1,000 while the records are being imported.To add a replace command to divide the values in the Loan Amount field by 1,000, followthese steps:15. Under Source, click theLoanAmount cell. Thenclick the ellipsis button.16. From the Functions window double-clickNumeric and doubleclick the RoundTo1000( )expression.14
Importing17. Single click INSIDE theparentheses ( ) in theExpression Creating window. In the column window use the scroll bar tolocate and double-click onLoanAmount. Click theValidate button.Note:If the expression does notvalidate, make sure the field namewas placed inside the parenthesescorrectly.18. Click OK, then Apply.15
Fair Lending Wiz Training Guide19. Verify that Loan Amountis now displayed in thousands.Now that you have rounded the loan amount to the nearest thousandduring the import process, you also want to set placeholders (emptyfields) to accept fair lending values when you import another file usingupdate into the file just imported.To set empty fields in your import format, follow these steps:20. You want to make use offields that are included inCRA/FL Wiz wheneverpossible. For example toinclude the Beacon Score,select the cell under theSource column called Beacon. Click under theSource column to activatethe drop-down menu.Select Empty .16
Importing21. A valid Beacon Scoreshould always come in asa 3-character number.Therefore, there is noneed to accept the defaultvalues of Numeric, with9 positions to the left ofthe decimal, and 3 positions to the right. Openthe drop-down list underdata type, and selectINTEGER.22. Follow the same processas above making LTV andBERatio active. Set bothfields to be Numeric9,15,2.By performing this task during the import process, your file will be readyto accept these fields when you combine, or Update, another file withadditional data. Once this step is completed, you will not have to perform this step during another import as long as you continue to use thisformat. Hit Next.There is one more thing that must be done to this file prior to performing the actual import. There was one field (BRANCH ID) where thefield name provided in the .CSV (comma separated value) file did notmatch the FL Wiz field name (BRANCHNUMB).17
Fair Lending Wiz Training Guide23. Scroll up slightly (about midway between Beacon andZip) until you findBranchnumb, which is currently grayed out. In thesource column for Branchnumb, click on None .Open the drop-down list,and click on Branch ID asthe field you wish to “map”to.24. The Branchnumb field isonly a single digit indicator. Set the Data type toCHAR, and the Size to 1.25. Because you will beimporting all records inthe source file, you do notneed to create a filter.Move to the next screenby clicking the Next button.18
Importing26. You are now brought tothe Thank You screen. Tosave the import format,check the box next toSave the DefinedImport Format andname your format in theopen box. Call your format Mortgage with FLFields.27. Select Import Now. Youalso want to make sureyou have the appropriateyear selected. The yearshould represent theAction Year of your file(in this case - 2006). If it isnot correct, select thedrop-down menu andchoose the correct year.Click Finish.28. The software will nowimport the records fromthe source file into the target file you have created.19
Fair Lending Wiz Training Guide29. Select Yes to view thesummary. Print a copy ofthe summary to have asdocumentation of the process. Once you haveprinted the summary,select File Exit.20
ImportingExercise 2: Updating an Existing FileNow that you have imported the file, you can add fair lending data froman additional file. This file must contain some type of unique identifier sothe fields can be associated with the appropriate record. ApplicationNumber, or Applnumb, is a good field to use because it is a unique field,meaning each record should have a distinct application number.Your system might not use the Application Number, however. Use whatever field, or combination of fields, that will provide the ability to “matchup” records between two files received from different systems.To import a file using the Update feature, follow these steps:1. Select Import Wizard.2. Leave the default, New Format, selected. Hit Next.21
Fair Lending Wiz Training Guide3. On the Source File Selectionscreen, click the Source DataType drop-down menu.Select Text.4. Navigate outside of CRA/FLWiz to select your source file.Click the Source AccessFile ellipsis button.5. Select the file to be imported(Additional Fair LendingFields.csv). Click Next.6. In the File Format Selectionscreen, leave Delimitedselected.22
Importing7. You need to set the RowDelimiter. Click the dropdown menu and select Carriage Return.8. Leave Text Qualifier set asNone.9. Click the box next to FirstRow Has Column Names.Click Next.10. The Text File ColumnDelimiter Selection screenprovides various types ofdelimiters. Leave the default,Comma, selected. ClickNext.23
Fair Lending Wiz Training Guide11. On the Target File Selectionscreen, click the drop-downmenu for Wiz File Type andselect Mortgage 2004.12. Select Update File, thenclick the Ellipsis button.13. Select the working file, thefile that you will use duringyour analysis (MortgageYTD for training purposes),then click Open.24
Importing14. Your file should be listedunder Update File in BankData. Click Next.15. Click Auto-Map Remaining Source Columns. Thisfunction will match, or“map”, columns found inyour source file to your targetfile, IF they matched the FLWiz field name. Scroll down,and you will see onlyApplnumb, Beacon, andLTV. What happened to theBERatio field?16. Locate the “grayed out” fieldcalled BERatio. In that row,click on the word None under Source. Open thedrop-down list, and selectBER. Set the Scale to 2, thenclick the Next button.25
Fair Lending Wiz Training Guide17. The Matching Column Selection screen allows you toselect the field to base thematches on. ApplicationNumber, or Applnumb,makes the most sense to usebecause it is unique. ClickNext.18. On the Update Optionsscreen, deselect all options.You do not want the systemto Append UnmatchedRecords to the UpdatedFile, because each“Unmatched Record” wouldonly have 4 fields (applnumb,beacon, beratio, and LTV).Quality errors COULD bechecked, but you are notreplacing any values thatwould affect quality edits, soit best not to. Click Next.19. Because you are importing allrecords, you do not need tocreate a filter. Click Next.26
Importing20. The system has now broughtyou to the Thank You screen.Save the import format asFair Lending Fields. Clickthe Import Now box, making sure the Select ActionYear is set to 2006. Click Finish. The software processesthe file through the importfunction and provides youwith a summary screen. ClickNo when asked to view thesummary.27
Fair Lending Wiz Training Guide28
Editing Data for Fair LendingChapter 2Editing Data for Fair LendingUpon completion of this lesson you will be able to:XEdit data for Fair Lending Analysis purposesXUse Replace commands to correct erroneous information in the FairLending DataXUse Modify Codes to make user-defined fields available in the FairLending models29
Fair Lending Wiz Training GuideOverviewA Fair Lending Analysis is no better than the data that you have available in your electronic file. Forexample, an excessively high (incorrect) value in the LTV field for an originated loan could very wellset the threshold for acceptable values. For example, assume that you have an originated loan for a49-year old male, white non-Hispanic borrower showing a loan-to-value ratio of 192%. Assume further that this is a middle-income individual who lives in a non-minority tract ( 10% minorities), andthe tract is also a middle-income tract. The value of 192% becomes the threshold for acceptance forevery fair lending comparison that can be done!Before you start any kind of fair lending analysis, you must review the data at your disposal, anddetermine if there are individual or systemic problems that could interfere with the analysis. Keepnotes as you do these reviews, as you will use the data for two purposes:30XTo know what filters need to be applied before some fair lendinganalyses are runXTo help your institution determine where the errors are comingfrom, and whether they are part of a larger issue that needs to becorrected
Editing Data for Fair LendingExercise 1: Reviewing DataFrom this point on, you will be using a file called FL Wiz Training File2006 Revised. It contains over 19,000 records, and has fields in it for theapplicants’ credit scores, back-end ratios (total debt-to-income ratios),LTVs, CLTVs, Length of Employment, and Length of Residence. Thefile also contains a field called “Loanprog”, which is a 10-characterdescription of the specific loan program that the applicant was applyingfor.To review the Fair Lending fields, follow these steps:1. Click on the Main button in the ViewBar, then click on File Management.2. Click on the Mortgage 2004folder. Right-click in thewhite area to the right of thefile list in the right panel,then select Install/Restorefrom the contextual menu.31
Fair Lending Wiz Training Guide3. Navigate to the location ofthe FLW Files, then doubleclick on FLW Training File2007.dat.4. The software will Install thefile, adding it to the list ofMortgage 2004 files, and provide a message explainingthat you should “Run UpdateCalculated Fields”. Click OK.5. Right-click on the newlyinstalled file, and select Update Calculated Fieldsfrom the contextual menu. Click Yes when the message regarding Locked Records appears, and OKwhen the completion message appears.32
Editing Data for Fair Lending6. Right-click on the file again, and select Edit fromthe contextual menu.7. When the file opens, it willmost likely open to the Current Record screen. Click onthe Browse tab.8. It is always a good idea tocheck the overall quality ofthe file before starting youranalysis. Click on the wordEDIT in the menu, thenselect Govt ExceptionSummary Report (All).9. The exception report showsall errors - Validity, Syntactical, and Quality. This reportshows ONLY Quality errors.This means that the file isproperly geocoded, and thatall required fields are filled inproperly. Close the reportwhen finished reviewing it.33
Fair Lending Wiz Training Guide10. .Right-click anywhere in thedata, and click on SelectColumns to View from thecontextual menu.11. Click on the blue link at thetop that says Unselect All.34
Editing Data for Fair Lending12. Starting at the top of the window, select thefollowing fields (use the scroll bar as necessary):12.1 Action12.2 Lien Status12.3 Loan Term12.4 Rate Lock Date12.5 APR12.6 Age12.7 Cust Credt12.8 LTV12.9 BERatio12.10 Noterate12.11 LenEmploy12.12 LenResid12.13 LoanProg12.14 CLTV12.15 Raw Rate Spread12.16 Click the X to close the Manage Columns toBrowse dialog.TipIf after clicking “Unselect All” you either click outside the dialog box, orclose it with the “X”, click the Options dropdown menu, and select“Select Columns to View” to restore the window.13. Since the APR is the firstmajor field, start the analysis by reviewing the valuescontained within thatfield. How many aremissing? How manyzeroes are included fororiginated loans? What isthe highest value for anoriginated loan? Clic
the Wiz geocoder. To be geocoded within the Wiz, the file must contain Address, City, State_abrv, and Zip. 14. Click the Auto-Map Remaining Source Columns link. This link automatically maps the fields in your Source col-umn and lists the fields in the Target column only if the source field matches the CRA/FL Wiz field name. If the software
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