Beginning in 2017, the Federal Financial Institutions Examination Council (FFIEC) opted to replace its population and demographic data (formerly drawing on the 2010 Census) with data from five-year estimates from the annual American Community Survey (ACS). As these more recent demographic data become integrated into fair lending compliance functions, it is worth considering the significant demographic changes that have continued to occur after the 2010 Census. These trends have important implications for fair lending analysis where protected class status must be inferred such as: auto lending, mortgage servicing, payday lending, credit cards, student lending and unsecured lending, as well as selected compliance activities such as assessing Community Reinvestment Act (CRA) compliance.
In this brief, we compare the 2011–2015 ACS data with the 2010 Census data, identify a number of key national trends, and explore the underlying changes in selected geographies. As fair lending compliance matters most commonly focus on census tracts as the most granular geographic division, this brief will follow suit with analysis at the census tract level. In concert with this research, we have created an interactive website that allows the user to create maps for all major metropolitan statistical areas (MSAs) in the US and explore the tract-level demographic changes.
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