ABA, July 6, 2021, Mystery Shopping: Taking the Mystery out of Fair Lending
Mystery shopping is a long-standing testing technique used by various agencies and entities to test for fair treatment in credit transactions, particularly in the housing market. The surging focus on racial equity across many different aspects of society and commerce includes more attention on fair lending practices at banks. For example, one of the immediate priorities for the Biden administration is to advance racial equity and civil rights. Similarly, racial equity is a current stated priority for the Consumer Financial Protection Bureau, with Acting Director Dave Uejio remarking, “It’s also time for the CFPB to take bold and swift action on racial equity. . . . This of course means that fair lending enforcement is a top priority and will be emphasized accordingly. But we will also look more broadly, beyond fair lending. . . .”
In November 2020, a study was released by the National Community Reinvestment Coalition regarding Paycheck Protection Program loans that used matched-pair testing. NCRC performed past matched-pair “mystery shopper” tests in 2017, 2019, and earlier in 2020.