In this article Marsha Courchane, Senior Contractor Rajeev Darolia and Peter Zorn of Freddie Mac examine some of the observed trends and changes in the types and levels of broker compensation that existed before the regulatory change that brought about the implementation of the Federal Reserve Board’s (FRB) new loan officer compensation rule. They also examine the variance in broker compensation across geographies, across lenders, across borrower types, and across loan products.
What is disparate impact testing?
Disparate impact testing requires quantitatively testing models for fairness with respect to classes of borrowers protected under the Equal Credit Opportunity...