That mortgage lenders have complex underwriting standards, often differing legitimately
from one lender to another, implies that any statistical model estimated to approximate these
standards, for use in fair lending determinations, must be misspecified. Exploration of the
sensitivity of disparate treatment findings from such statistical models is, thus, imperative. We
contribute to this goal. This article examines whether the conclusions from several bank-
specific studies, undertaken by the Office of the Comptroller of the Currency, are robust to …

The binary logistic regression or logit link model is commonly used to test for racial disparate
treatment in fair lending studies undertaken by government agencies, including the Office of
the Comptroller of the Currency (OCC) and the Federal Reserve Board (FRB). Ensuring race
neutrality in lending remains a concern of regulators and consumer advocates. Improving
the understanding of any shortcomings of either bank internal models or regulatory agency
models will enable those participants in the mortgage industry to better serve the needs of …