Strategic Responses to Bank Regulation: Evidence From HMDA Data

The intent of fair lending regulation is to encourage loans in low-income areas and ensure that loan decisions are based on economic criteria instead of noneconomic borrower characteristics. We evaluate situations in which banks may find it in their self interest to respond to regulation in a strategic manner intended to improve public relations and appease regulators rather than to adhere to the true spirit of the regulation. We find some evidence consistent with such behavior.