FFIEC announces release of 2018 HMDA data

The 2018 national loan-level Home Mortgage Disclosure Act (HMDA) data has been released by the Federal Financial Institutions Examination Council (FFIEC).  The data includes, for the first time, the expanded set of data points required by the new HMDA rule.  As my partner Richard Horn has written about before here, the public 2018 data is modified for privacy reasons under a CFPB final policy issued in December 2018. HMDA data has long been the most comprehensive, publicly available data-set on mortgage market activity.  The data covers mortgage lending transactions at over 5,000 financial institutions.  The data can be accessed here and the FFIEC press release is available here.

HMDA data provides critical information for financial regulators, including those examining for fair lending, consumer protection and Community Reinvestment Act (CRA) compliance.  HMDA data can also help the public assess how financial institutions are serving the housing needs of their local communities.  The data also can be used by market analysts to assess macro trends in the mortgage market.

The new data includes 48 data points, covering information about applicants, underlying properties and  types of loans.  In 2018 there were approximately 12.9 million loan applications and approximately 7.7 million loan originations (a decrease from 2017 by 12.6 percent).  As most readers of this blog will know, the data also includes several new fields for the first time including:  disaggregated race and ethnicity, age, credit score information, and ratios for loan-to-value and debt-to-income.  In addition, the 2018 data contains data on home equity lines of credit (HELOC), commercial purpose loans and reverse mortgages. A complete list of the data points can be found here

This data follows the release, in March 2019, of Loan Application Registers (LARs) for each HMDA filer, modified for borrower privacy.  In addition to the HMDA data, two articles were released by the Consumer Financial Protection Bureau (CFPB).  The first provides initial observations about the mortgage market based on the newly available data fields.  The second continues a series of reports describing mortgage market activity over time.

Garris Horn frequently represents clients interpreting CFPB initiatives and rules.  For more information on this data release, or to discuss any other CFPB-related matters, contact Troy Garris directly at 301-461-8952 or troy@garrishorn.com.

Troy Garris

Troy is a business owner’s lawyer, priding himself on a results-oriented, pragmatic approach to addressing legal issues in the financial services world. In his words, “I find out what the business wants, what it needs. If I start there, I can often find a way to get them to the result wanted, or very close to it, in a legal and compliant way.”

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