Finance and Economics Discussion Series: Accessible versions of figures for 2026-010

Enforcing Fair Lending: Evidence from Mortgage Market Litigation

Accessible version of figures


Figure 1: Black-White Denial Disparity Over Time
 

Note: Estimated denial rate disparities between Black and White applicants over time at banks subject to litigation. Estimated denial disparities only include by-year disparities at such banks, with the year that litigation was filed defined as 0. The figure does not include overall racial disparities at such banks, nor does it include industry-wide denial disparities.

Figure 1 Figure Type: Line chart with 95% confidence intervals Title: Black-White Denial Disparity Over Time Axes: X-axis: Year Relative to Litigation Filing (ranging from -4 to 4) Y-axis: Denial Rate Disparity in percentage points (ranging from -10 to 10) Data Series: Denial Rate Disparity vs Competitors (black line with square markers and gray confidence interval bars) Data Points: Year -4: approximately 2.0 percentage points Year -2: approximately -2.5 percentage points Year -1: approximately 4.0 percentage points (peak) Year 0 (litigation filing): approximately 0.0 percentage points Year 1: approximately -2.0 percentage points Year 2: approximately -5.0 percentage points (lowest point) Year 3: approximately -4.0 percentage points Year 4: approximately -4.0 percentage points Key Trends: The figure shows a change in denial rate disparities between Black and White mortgage applicants at banks subject to fair lending litigation relative to their local competitors. Before litigation, disparities fluctuate, with a peak of approximately 4 percentage points in year -1. At the time of litigation filing (year 0), the disparity drops sharply to near zero. Following litigation: from year 1 onward, the relative disparity becomes negative and stabilizes around -4 percentage points.

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Figure 2: Black-White Denial Disparity Over Time, Relative to Disparity Pre-Litigation
 

Note: Estimated denial rate disparities between Black and White applicants over time at banks subject to litigation, relative to the pre-litigation disparity at litigated banks.

Figure Type: Line chart with 95% confidence intervals Title: Black-White Denial Disparity Over Time, Relative to Disparity Pre-Litigation Axes: X-axis: Year Relative to Litigation Filing (ranging from 0 to 4) Y-axis: Denial Rate Disparity in percentage points (ranging from -8 to 4) Data Series: Denial Rate Disparity vs Competitors relative to Pre-Litigation (black line with square markers and gray confidence interval bars) Reference Line: Horizontal line at 0 percentage points (red/pink dashed line representing the pre-litigation baseline) Data Points: Year 0 (litigation filing): approximately -1.0 percentage points Year 1: approximately -3.0 percentage points Year 2: approximately -6.0 percentage points (lowest point) Year 3: approximately -5.0 percentage points Year 4: approximately -5.0 percentage points Key Trends: The figure shows the change in denial rate disparities between Black and White mortgage applicants at banks subject to fair lending litigation relative to their local competitors, normalized to the pre-litigation disparity level. At the time of litigation filing (year 0), the relative disparity is approximately -1 percentage point below the pre-litigation baseline. The disparity continues to decline, reaching its lowest point of approximately -6 percentage points in year 2. From year 3 onward, the relative disparity stabilizes around -5 percentage points, indicating a sustained reduction in denial rate disparities compared to the pre-litigation period.

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Figure 3: Post-litigation Change in Black Applicant Denial Rate Across Litigated Banks
 

Note: The Y axis reports the change in the Black-White disparity in denial rates (measured in percentage points), relative to pre-litigation. Markers sized by lender’s post-litigation loan volume. Not pictured: the post-litigation trend at First United Security Bank following US v. First United Security Bank (2009). In that litigation, which we exclude here given how much of an outlier result it is, the Black-White denial disparity increased by a statistically significant 58 percentage points after litigation.

Figure 3 Figure Type: Scatter plot with 95% confidence intervals and combined estimate Title: Post-litigation Change in Black Applicant Denial Rate Across Litigated Banks Axes: X-axis: Individual litigated banks/cases (not explicitly numbered; approximately 20+ cases shown from left to right) Y-axis: Change in Black-White denial disparity in percentage points (ranging from -4 to +0.1) Data Series: Case specific estimates: Individual circles with vertical confidence interval bars. Circle size represents lender's post-litigation loan volume (larger circles indicate higher loan volumes) Combined estimate: Horizontal dashed line (blue) at approximately -3.9 percentage points Reference line: Horizontal line at 0 percentage points (black) Data Points: The scatter plot shows approximately 20+ individual case estimates with varying confidence intervals. Key Trends: The figure displays case-by-case variation in the post-litigation change in Black applicant denial rates across litigated banks. Most cases show negative values, indicating a reduction in the Black-White denial disparity following litigation. Larger circles, representing banks with higher post-litigation loan volumes, tend to cluster in the negative range. The wide range of estimates (from slightly positive to approximately -20 percentage points) demonstrates substantial heterogeneity in outcomes across litigated institutions, with most showing decreased denial disparities for Black applicants post-litigation.

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Figure 4: Cases Reviewed But Excluded from Our Sample

Case Reason for Exclusion
Church of Zion Christian Center v. Southtrust Bank Private non-class suit that didn't center mortgage loans
Housing Opportunities Made Equal a/k/a HOME v. Nationwide Insurance Insurance redlining, not mortgage redlining
Sallion v. Suntrust Banks, Inc. Mortgage discrimination but class cert denied on appeal
Milton v. Bancplus Mortgage Corporation Mortgage discrimination but class cert denied on appeal
US v. Auto Fare (2014) Auto lending market, not mortgage
US v. Synchrony Bank f/k/a GE Capital Retail Bank (2014) Credit card lending
US v. Fifth Third Mortgage (2014) disability discrimination
US v. First United Bank (2014) consumer loans, not mortgages
US v. Sallie Mae (2014) pre service loans, not mortgages
US v. Santander (2014) unlawful repossession of automobiles
US v. American Honda Finance Corp (2015) Auto lending
US v. Fifth Third Bank (2015) Auto Lending
US v. Toyota Motor Credit Corp (2015) Auto lending
US v. Evergreen Bank Group (2015) motorcycle lending
US v. Evolve Bank & Trust (2015) disability discrimination
US v. Charter Bank (2016) vehicle secured consumer loans
US v. The Home Loan Auditors (2016) mortgage loan modification
US v. First Federal Bank of Florida (2016) discriminiation on basis of familial status(maternity)
US v. Hatfield (2017) sexual harrassment
US v. COPOCO Community Credit Union (2017) illegal auto repossession
US v CitiFinancial Credit Co (2017) illegal auto repossession
US v. Westlake Services (2017) illegal auto repossession
US v. Wells Fargo Bank, N.A., d/b/a Wells Fargo Dealer Services (2017) illegal auto repossession
US v. Northwest Trustee Services (2017) illegal home foreclosure
US v. Advocate Law Groups of Florida (2018) mortgage loan modification
US v. BMW Financial Services (2018) Motor vehicle lease terminations
US v. Northwest Trustee Services (2018) Home foreclosures
US v. Hudson Valley Federal Credit Union (2018) illegal auto repossession
US v. California Auto Finance (2018) illegal auto repossession
US v. Guaranteed Auto Sales (2019) race discrimination on auto loans
US v. Nissan Motor Acceptance Corp (2019) Auto repossessions
US v. PHH Mortgage Corp (2019) home forclosures
US v. Bank of America (2020) discrimination on basis of disability
US v. Conn Credit (2021) overcharged interest rates
US v. New Jersey Higher Education Student Assistance Authority (2021) Student loan case
US v. Ally Financial Inc and Ally Bank (2013) auto lending
US v. Nara Bank (2013) auto lending
US v. Bank of America (2012) discrimination on basis of disability
US v. Union Auto Sales (2012) Discrimination in auto lending
US et al., v. Bank of America Corp., et al. (2012) Not discrimination on basis of race
US v. Capital One (2012) not a mortgage case
US v. Nixon State Bank (2011) consumer loans
US v. Mortgage Guaranty Insurance Corp (2011) sex based discrimination
US v BAC Home Loans Servicing (2011) wrongful foreclosure
US v Saxon Mortgage Services (2011) wrongful foreclosure
US v. Nationwide Nevada (2008) refused to purchase automobile contracts based on ethnicity
US v. Compass Bank (2007) Discrimination on basis of marital status
US v. Springfield Ford (2007) Discrimination on car loan rates
US v. Pacifico Ford (2007) Discrimination on car loan rates
US v. First Nat'l Bank of Pontotoc (2007) sexual harassment of female borrowers
US v. Fifth Third Bank (2004) discrimination on basis of race for business loans
US v. Fidelity Federal Bank (2002) credit card program discrimination
US v. Associates National Bank (2001) credit card program discrimination
US v. Deposit Guaranty National Bank (1999) Home improvement loan discrimination
Cason v. Nissan Motor Acceptance Corp (2000) higher finance charges for African Americans at Nissan Dealerships
Louisiana ACORN Fair Housing v. LeBlanc (1998) rent discrimination
Regional Economic Community Action Program, Inc. v. City of Middletown (1998) discrimination against alcoholics
US v. Big D Enterprises (1998) Discrimination against African American renters
US v. City of Lake Station (1998) City refused to permit development of affordable, owner occupied, single family homes
US v. City of Toledo (1998) discrimination on basis of disability
US v. Crawford (1998) sexual harassment
US v. Damron (1998) refused to rent to African Americans
US v. Gardner (1998) discrimination against children
US v. Inland Empire Builders (1998) discrimination on basis of disability
US v. Krueger (1998) sexual and racial harassment of black tenants
US v. Lexington Village Apartments and Hillcrest Village (1998) defendant not a mortgage originator
US v. Nejam Properties (1998) defendant not a mortgage originator
US v. Richmond (1998) defendant not a mortgage originator
US v. Vernon (1998) defendant not a mortgage originator
US v. Village of Addison (1998) defendant not a mortgage originator
US v. Housing Authority of the Town of Milford (1997) defendant not a mortgage originator
US v. Las Vegas Jaycees Senior Citizens Mobile Home Community (1997) defendant not a mortgage originator
US v. Nationwide Mutual Insurance (1997) Discrimination in home insurance
US v. Rock Springs Vista Development Corp (1997) defendant not a mortgage originator
US v. Town of Cicero (1997) defendant not a mortgage originator
US v. Williams (1997) defendant not a mortgage originator
US v. Associates National Bank (1997) discrimination in credit card applications
US v. Big D Enterprises (1997) defendant not a mortgage originator
US v. Choice Property Consultants (1997) defendant not a mortgage originator
US v. City of Milwaukee (1997) defendant not a mortgage originator
US v. Hagadone (1997) defendant not a mortgage originator
US v. Harlan (1997) defendant not a mortgage originator
US v. JDL Management (1997) defendant not a mortgage originator
US v. Cedar Builders (1996) defendant not a mortgage originator
US v. City of Waukegan (1996) defendant not a mortgage originator
US v. Village of Hatch (1996) defendant not a mortgage originator
US v. American Family Mutual Insurance (1995) defendant not a mortgage originator
US v. City of Pharma (1995) defendant not a mortgage originator
US v. Pinewood Associates (1995) defendant not a mortgage originator
US v. Secutiry State Bank (1995) discrimination in consumer loans
US v. Veal (1994) defendant not a mortgage originator
US v. Blackpipe State Bank (1994) not discrimination on mortgages
US v. Chevy Chase Bank (1994) not discrimination on mortgages
US v. First National Bank of Vicksburg (1994) Home improvement loan discrimination
US v. Jacksonville Housing Authority and City of Jacksonville (1994) defendant not a mortgage originator
US v. Nedialkov (1994) defendant not a mortgage originator
US v. Flagstar Corporation and Denny's (1993) not discrimination on mortgages
US v. Plaza Mobile Estates (1991) defendant not a mortgage originator

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