To:

Ms. Amy Pyle
Editor in Chief
Aaron Glantz
Senior Reporter
Center for Investigative Reporting
1400 65th St., Suite 200
Emeryville, CA 94608

From:

HomeServices of America, Inc

Date:

26 April 2018

Re:

CIR, Reveal Response

On Monday, April 23, 2018, HomeServices of America, Inc. received an e-mail from Aaron
Glantz, a reporter with Reveal & The Center for Investigative Reporting (CIR). Mr. Glantz
informed us that CIR planned to publish an additional piece in a series about whether mortgage
lenders engage in discriminatory practices.
HomeServices of America appreciates this opportunity to provide accurate context for the
forthcoming story. In particular, our three wholly owned mortgage lenders—Prosperity Mortgage,
HomeServices Lending, and Trident Mortgage—welcome this opportunity to demonstrate that
their commitment to lending transparency and integrity goes well beyond complying with the law
to ensuring that everyone—regardless of their race, ethnicity, gender, or other protected status—
is treated equally and fairly. The culture of all HomeServices of America companies demands
nothing less than an unwavering commitment to integrity and fairness. We are confident in our
record.
HomeServices of America takes seriously any allegation of discrimination. Our lenders have
constantly focused on improving access to mortgage loans in minority communities through
several initiatives and outreach efforts discussed below. We share the view of many in the lending
industry that, although progress has been made in this area, more needs to be done. We want to
ensure that everyone who is qualified to obtain a mortgage loan can do so.
Unfortunately, the lending data that CIR has presented to us in seeking comment for the
forthcoming story (a) focuses only on conventional loans and ignores other loan products such as
government-sponsored loans; (b) is based on 2015 and 2016 data whereas the 2017 data now
publicly available show a continued increase in market penetration; and (c) ignores other
creditworthiness considerations (e.g., loan-to-value and debt-to-income ratios). In fact, the lenders’
continuing efforts to attract more applications from minority borrowers are making a difference.

HSOA-00022285.6

 Some examples of this outreach to minority communities include:
x

In 2017, HomeServices Lending conducted its first ever direct-marketing campaign to the
public. That campaign was specifically aimed at majority-minority communities to increase
opportunities for potential homebuyers.

x

In 2018, Trident Mortgage launched a similar campaign in many Philadelphia majorityminority areas as well as in Camden, New Jersey and Allentown, Pennsylvania to attract
minority applicants.

x

Each lender engages in some combination of the following activities aimed at increasing
outreach to majority-minority areas: partners with minority professional associations in the
industry; engages in lead purchases directly targeting majority-minority communities;
sponsors and coordinates with non-profit organizations, local housing authorities, and
mortgage-assistance programs to foster partnerships with the goal of increasing minority
homeownership.

x

Each lender identifies opportunities to increase lending in minority communities including
offering bond and down-payment-assistance programs.

x

The lenders actively recruit diverse candidates and are committed to cultivating a diverse
workforce.

x

The lenders have bilingual and multilingual loan officers, are actively recruiting additional
candidates, and have implemented resources to specifically accommodate applicants with
limited English proficiency.

CIR also suggests that our lenders are trying to ensure that they don’t get applications from people
of color. This is categorically false.
x

The lenders have taken steps to reduce and mitigate fair-lending risks by strengthening their
compliance-management systems.

x

They conduct annual training of all their employees on Fair Lending, ECOA, HMDA, RESPA,
and other critical regulations.

x

They conduct periodic monitoring and testing of files and processes to ensure consistent
treatment of files and applicants and implement internal audit programs to assess fair-lending
performance.

x

Their executive teams are integrally involved in reviewing fair-lending practices and setting
the tone for compliance as well as fair and ethical business practices.

x

They ensure all marketing materials reflect the diversity of the communities they serve.

x

They have increased outreach in their communities to establish a presence where one otherwise
would not exist since they do not traditionally market directly to consumers.

In keeping with your own journalistic guidelines that provide that “subjects of our stories should
have many opportunities to respond to our findings and facts,” we anticipate that CIR’s reporting
will provide all the information set forth here in a readily accessible manner so that the public is
fully informed of all the pertinent facts, and receives a fair and balanced narrative of these
important issues.

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