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Scan 02 · Marketing

Run your own marketing fair lending scan

A marketing scan compares who applied to you with who lives in the market you serve, by race and ethnicity together. HMDAVision builds it from loan-level HMDA against Census population, tracks the gap across four years, and converts it into the number of applications that would close it.

Free tier is three answers a day, fifteen a month, no card.

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What marketing risk is

Regulation B prohibits any statement or practice, in advertising or otherwise, that would discourage a reasonable person from applying on a prohibited basis.

Regulation B, 12 CFR 1002.4(b)

Marketing risk is the quiet version of a fair lending problem. No one is denied. The applications simply never arrive from part of the market, and the application register shows it before any complaint does. The scan measures that absence.

The red flags a scan is looking for

01

A gap that holds for years

The same group under-represented in applications across every HMDA release, with no trend toward closing.

02

A gap peers do not show

Lenders of similar size in the same market receiving applications from a group at a rate you are not.

03

Thin applications where population is dense

Tracts with a large share of a group and few applications from it, which the redlining map shows directly.

04

A blended average hiding a split

Hispanic White and Hispanic of two or more races moving in opposite directions inside one Hispanic total.

05

Growth that widens the gap

Total applications rising while the under-represented group's share stays flat or falls.

06

Channel doing the sorting

One group arriving mostly through brokers or correspondents while another arrives through retail.

The scan itself

Application mix against people mix, by Minority Detail

Minority Detail crosses race with ethnicity, so each row is a specific group rather than a blended average. The 2022 to 2025 gap columns show whether the distance is closing. The last column converts the current gap into applications.

Marketing risk by applications, 2025
Minority detailApplications mixPeople mix2025 gapApps to close
Non-Hispanic White78.8%74.6%+4.2—
Non-Hispanic Asian7.5%5.1%+2.4—
Non-Hispanic Black5.4%8.1%−2.6598
Non-Hispanic, two or more races1.9%6.0%−4.2944
Hispanic, two or more races0.5%3.8%−3.3753
Hispanic White4.1%1.4%+2.7—
All groups22,714 apps899,262 people——

One metro, all lenders, 2025 applications from HMDA against Census population, applications with race or ethnicity not available excluded. Select your institution and the same table shows your own mix against the same people.

What the scan says

Non-Hispanic Black residents are 8 percent of this market and 5 percent of its applications. The gap has held between 2.2 and 2.7 points since 2022. Closing it at the market level takes 598 applications; your share of that is your target.

Read with care

Applications where race or ethnicity was not reported are excluded. A lender with a high not-available share has a data question before a marketing one.

Then check

Whether the gap is the whole market's or yours alone. A gap every lender shares is a demand question. A gap only you show is a reach question.

The workflow

Six steps, fully reproducible

Each step is a set of filters in HMDAVision. Keep them and the scan reruns on the next HMDA release in minutes.

1

Define the market you serve

Assessment area, field of membership, or the geography your lending and advertising reach. The population baseline is built from it.

Output: a defined market with a documented rationale.

2

Read the market-level table first

All lenders, all groups, four years of gaps. This is the demand picture your own numbers will be read against.

Output: which gaps belong to the market, and which do not.

3

Select your institution

The same table, your applications only. Compare each row's gap to the market row and to peers of similar volume.

Output: the groups where your reach trails the market.

4

Convert the gap to applications

The last column does the arithmetic. It is the number a marketing plan and a compliance memo can both use.

Output: an application target by group.

5

Locate it on the map

Open the redlining view with the same filters. The tracts where population is dense and your applications are thin are where the target lives.

Output: a target with a geography attached.

6

Record the filters and repeat

Year, geography, action type, group definition. The next release shows whether the gap moved.

Output: a trend line, and an audit trail.

From finding to action plan

The gap is a compliance finding and a pipeline target at once

A compliance officer reads 598 applications as exposure. A marketing lead reads it as demand no campaign is reaching. Same table, same afternoon. What changes is who is looking and what they do next.

Where to put spend

Advertising that reaches the whole market is both a Regulation B expectation and the cheapest source of applications you are not receiving. The tract list from step five is the media plan.

Which partners

The lenders already receiving those applications show which agents, builders and community organizations are in the flow. The referral partner view names them by tract.

What to measure next quarter

Rerun the same filters. A gap that narrows is evidence of a working program, produced by you rather than purchased.

Start scanning

See where your marketing is landing, and where it is not.

Ask one question at mortgagedata.ai, or open the full table on your own institution with a guided seven-day trial of HMDAVision.

Polygon Research is a research and analytics firm, not a law firm. Nothing here is legal advice, and a fair lending program should be built with counsel.