CA 18-9: Designated Home Mortgage Disclosure Act Key Data Fields

BOARD OF GOVERNORS
OF THE FEDERAL RESERVE SYSTEM
WASHINGTON, D.C. 20551

DIVISION OF CONSUMER
AND COMMUNITY AFFAIRS

CA 18-9
December 7, 2018

TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS:

SUBJECT:

Designated Home Mortgage Disclosure Act Key Data Fields

Applicability to Community Banking Organizations: This guidance applies to all institutions supervised by the Federal Reserve, including those with total consolidated assets of $10 billion or less.

The Board of Governors of the Federal Reserve System (Board), working in consultation with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), has developed updated information regarding the Home Mortgage Disclosure Act (HMDA) key data fields that Federal Reserve examiners use in connection with validating the accuracy of HMDA data collected since January 1, 2018 pursuant to the Bureau of Consumer Financial Protection’s (Bureau) October 15, 2015 and August 24, 2017 amendments to Regulation C (Home Mortgage Disclosure) and the Economic Growth, Regulatory Relief, and Consumer Protection Act’s (EGRRCPA) May 24, 2018 amendments to HMDA.1

HMDA and Regulation C require certain depository institutions and for-profit non-depository institutions to collect, report, and disclose data about originations and purchases of mortgage loans as well as mortgage loan applications that do not result in originations. Section 1094 of the Dodd-Frank Wall Street Reform and Consumer Protection Act transferred rulemaking authority for HMDA to the Bureau, effective July 2011; amended HMDA to require collection, recording, and reporting of new data points; and authorized the Bureau to require additional information from covered institutions.2

The Bureau issued an August 31, 2018 interpretive and procedural rule to implement and clarify the EGRRCPA amendments to HMDA, which provide partial exemptions for some insured depository institutions and insured credit unions from certain HMDA requirements.3 The partial exemptions are generally available to insured depository institutions and insured credit unions: (1) for closed-end mortgage loans, if the institution originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years; and (2) for open-end lines of credit, if the institution originated fewer than 500 open-end lines of credit in each of the two preceding calendar years. For closed-end mortgage loans or open-end lines of credit subject to the partial exemptions, those institutions are exempt from the collection, recording, and reporting requirements for 26 of the 48 data points specified in current Regulation C, but remain responsible for collecting, recording, and reporting the remaining 22 data points.

In October 2017, the Board, the FDIC, and the OCC designated 37 HMDA data fields as “HMDA key data fields” because they collectively determined those fields to be most critical to the integrity of the analyses of overall HMDA data.4 The HMDA key data fields do not affect an institution’s collection, recording, and reporting obligations. Rather, they are used in conjunction with the Federal Financial Institutions Examination Council (FFIEC)5 sampling, verification, and resubmission procedures (FFIEC HMDA Examiner Transaction Testing Guidelines) for HMDA data collected from January 1, 2018 onward, which were transmitted with CA 17-2.6 Once examiners have selected a random sample of entries from an institution’s HMDA Loan Application Register (HMDA LAR) and have received the corresponding loan files, they would verify the accuracy of the applicable HMDA key data fields in the entries in the HMDA LAR sample(s) against information in the loan files.7

For institutions eligible for a partial exemption, the partial exemption covers 16 of the HMDA key data fields, which means that only 21 of the 37 designated HMDA key data fields remain among the data fields that they are responsible for collecting, recording, and reporting.8

The FFIEC members are currently developing a comprehensive set of revised interagency HMDA examination procedures regarding HMDA requirements relating to data collected from January 1, 2018 onward. The FFIEC HMDA Examiner Transaction Testing Guidelines and the HMDA key data fields will be incorporated into those revised examination procedures.

With regard to HMDA data collected prior to January 1, 2018, Reserve Banks will continue to examine financial institutions pursuant to the interagency HMDA examination procedures transmitted with CA 09-10 and the HMDA sampling and resubmission procedures (including legacy HMDA key data fields) transmitted with CA 04-4.

If you have any questions, please contact Amal Patel, Counsel, at (202) 912-7879, or Meghan Karellas, Acting Manager, at (202) 736-5536. In addition, questions may be sent via the Board’s public website.9

signed by
Suzanne Killian
Senior Associate Director
Division of Consumer and Community Affairs

Supersedes:

• CA 17-3 “Designated Home Mortgage Disclosure Act Key Fields” (October 17, 2017)

Attachments:

Designated Home Mortgage Disclosure Act (HMDA) Key Data Fields

Cross References:

• CA 18-6 “Statement on the Implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act Amendments to the Home Mortgage Disclosure Act” (July 5, 2018)
• CA 17-4 “Expectations for Supervised Institutions Regarding Amended Regulation C”(December 21, 2017)
• CA 17-2 “Revised Interagency Home Mortgage Disclosure Act Sampling, Verification, and Resubmission Procedures” (August 22, 2017)
• CA 09-10 &lqduo;Revised Interagency Examination Procedures for the Home Mortgage Disclosure Act” (October 1, 2009)
• CA 04-4 “Revised HMDA Examination, Sampling and Resubmission Procedures and Notification of Availability of HMDA Questions and Answers” (June 30, 2004)

Notes:

1. See 80 FR 66127 (October 28, 2015); 82 FR 43088 (September 13, 2017); Pub. L. 115-174, 132 Stat. 1296 (2018), section 104(a) (codified at 12 U.S.C. 2803). Return to text
2. Pub. L. 111-203, 124 Stat. 1376 (2010). Return to text
3. 83 FR 45325 (September 7, 2018). Return to text
4. See CA 17-3. Return to text
5. The FFIEC members are the Board, the Bureau, the FDIC, the National Credit Union Administration, the OCC, and the State Liaison Committee. Return to text
6. Although the FFIEC HMDA Examiner Transaction Testing Guidelines themselves do not establish key data fields, they state that supervisory agencies may establish a HMDA data sampling process that prioritizes designated fields for review. Return to text
7. However, consistent with the FFIEC HMDA Examiner Transaction Testing Guidelines, there may be certain circumstances in which Board and Reserve Bank staff determine that it is necessary to review additional HMDA data fields. Return to text
8. As indicated in the Bureau’s interpretive and procedural rule, institutions subject to a partial exemption may optionally report HMDA data covered by that partial exemption. Return to text
9. See http://www.federalreserve.gov/apps/contactus/feedback.aspx. Return to text

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Designated Home Mortgage Disclosure Act (HMDA) Key Data Fields The Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) have designated HMDA key data fields to support the efficient and effective evaluation of financial institutions’ compliance with HMDA’s requirements. The Home Mortgage Disclosure Act (HMDA), which is implemented by Regulation C, 12 C.F.R. 1003, requires certain financial institutions to collect, record, and report information about their mortgage lending activity.1 The Bureau of Consumer Financial Protection’s (Bureau) amendments to Regulation C (HMDA Amendments)2 and section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA)3 establish the data to be collected.4 For the purpose of ensuring compliance with HMDA’s requirements, traditionally the Board, the FDIC, and the OCC have identified and focused examination-related testing of HMDA data on certain agency-designated “key fields.” Key fields are those data fields considered to be most important to ensuring the integrity of analyses of overall HMDA data. Separately, the FFIEC members have issued FFIEC HMDA Examiner Transaction Testing Guidelines (FFIEC Guidelines) for the FFIEC members’ examination staffs to use in assessing the accuracy of the HMDA data that financial institutions collect, record, and report.5 The FFIEC Guidelines include a data sampling process that involves prioritizing designated data fields for review or reviewing all data fields within a sample. However, the FFIEC Guidelines themselves do not establish designated HMDA key data fields. In an effort to promote efficiency, coordination, and consistency, the Board, the FDIC, and the OCC have jointly identified and designated 37 of the HMDA data fields to be collected since January 1, 2018, pursuant to the HMDA Amendments, as Designated HMDA Key Data Fields. For institutions eligible for a partial exemption pursuant to EGRRCPA,6 21 of the 37 Designated

1 12 U.S.C. 2801 et seq. 2 80 FR 66127 (October 28, 2015); 82 FR 43088 (September 13, 2017). 3 132 Stat. 1296 (2018), section 104(a) (codified at 12 U.S.C. 2803). 4 Beginning with data collected on or after January 1, 2018, financial institutions subject to HMDA collect and report data on covered loans specified in 12 C.F.R. § 1003.4(a)(1)-(38) on a loan application register (LAR) containing 110 “data fields,” as specified in the applicable Federal Financial Institutions Examination Council (FFIEC) Filing Instructions Guide (FIG), available through the FFIEC HMDA File Specifications webpage at https://www.ffiec.gov/hmda/fileformats.htm or with other FFIEC HMDA resources at https://ffiec.cfpb.gov/. 5 The FFIEC members are the Board, the Bureau, the FDIC, the National Credit Union Administration, the OCC, and the State Liaison Committee. The FFIEC members promote compliance with federal consumer protection laws and regulations through supervisory and outreach programs. Among these laws and regulations is HMDA. 6 Provided that they are not subject to the exception to the partial exemptions for adverse Community Reinvestment Act (CRA) examination history, insured depository institutions eligible for a partial exemption are not required to collect, record, and report certain HMDA data points specified in EGRRCPA, as further explained in the Bureau’s interpretive and procedural rule to clarify and implement the legislation (83 FR 45325 (September 7, 2018)). Various HMDA data points are associated with multiple HMDA data fields. Financial institutions subject to a partial exemption also collect and report their HMDA data, on a LAR, as specified in the applicable FIG.

HMDA Key Data Fields are among the data fields that they remain responsible for collecting, recording, and reporting. In identifying Designated HMDA Key Data Fields, the Board, the FDIC, and the OCC considered a variety of factors, including HMDA’s requirements, the goal of ensuring the efficiency of bank examinations, and the effective validation of HMDA data important to evaluating compliance with the CRA and fair lending requirements. The Board, the FDIC, and the OCC also took into account the likelihood that a data field would be reported correctly based on past examination experience. Accordingly, for the purpose of evaluating financial institutions’ compliance with HMDA requirements, the Board, the FDIC, and the OCC will focus primary attention on the Designated HMDA Key Data Fields during transaction testing for HMDA data collected on or after January 1, 2018.7 However, in certain circumstances, consistent with the FFIEC Guidelines, examination staff may determine that it is necessary to review additional HMDA data fields, as appropriate.
Table 1 lists all 110 HMDA data fields and their corresponding HMDA data points. The 37
Designated HMDA Key Data Fields applicable to financial institutions not eligible for an EGRRCPA partial exemption from HMDA’s data collection, recording, and reporting requirements are shown in italicized bold text. The 21 Designated HMDA Key Data Fields applicable to financial institutions that are eligible for an EGRRCPA partial exemption from HMDA’s data collection, recording, and reporting requirements are identified by an asterisk (*).
Table 2 solely lists the 37 Designated HMDA Key Data Fields (Column B) applicable to
financial institutions not eligible for an EGRRCPA partial exemption from HMDA’s data collection, recording, and reporting requirements and, separately, the 21 Designated HMDA Key Data Fields (Column C) applicable to financial institutions that are eligible for an EGRRCPA partial exemption from HMDA’s data collection, recording, and reporting requirements.

Furthermore, as indicated in the Bureau’s interpretive and procedural rule, institutions eligible for a partial exemption may nevertheless opt to report HMDA data covered by that partial exemption. 7 Each agency shall operate in accordance with its supervisory authority.

Table 1

Data Field Name Data Point Name

1 Record Identifier – Value is 2
2 Legal Entity Identifier (LEI) Legal Entity Identifier (LEI) 3 Universal Loan Identifier (ULI) or Non-Universal Loan Identifier (NULI) Universal Loan Identifier (ULI) or Non-Universal Loan Identifier (NULI) 4 Application Date* Application Date* 5 Loan Type* Loan Type* 6 Loan Purpose* Loan Purpose* 7 Preapproval Preapproval 8 Construction Method Construction Method 9 Occupancy Type* Occupancy Type* 10 Loan Amount* Loan Amount* 11 Action Taken* Action Taken* 12 Action Taken Date* Action Taken Date* 13 Street Address Property Address 14 City Property Address 15 State Property Location & Property Address 16 ZIP Code Property Address 17 County Property Location 18 Census Tract* Property Location* 19 Ethnicity of Applicant or Borrower: 1* Ethnicity* 20 Ethnicity of Applicant or Borrower: 2 Ethnicity 21 Ethnicity of Applicant or Borrower: 3 Ethnicity 22 Ethnicity of Applicant or Borrower: 4 Ethnicity 23 Ethnicity of Applicant or Borrower: 5 Ethnicity 24 Ethnicity of Applicant or Borrower: Free Form Text Field for Other Hispanic or Latino Ethnicity 25 Ethnicity of Co-Applicant or Co-Borrower: 1* Ethnicity* 26 Ethnicity of Co-Applicant or Co-Borrower: 2 Ethnicity 27 Ethnicity of Co-Applicant or Co-Borrower: 3 Ethnicity 28 Ethnicity of Co-Applicant or Co-Borrower: 4 Ethnicity 29 Ethnicity of Co-Applicant or Co-Borrower: 5 Ethnicity 30 Ethnicity of Co-Applicant or Co-Borrower: Free Form Text Field for Other Hispanic or Latino Ethnicity 31 Ethnicity of Applicant or Borrower Collected on the Basis of Visual Observation or Surname Ethnicity 32 Ethnicity of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname Ethnicity 33 Race of Applicant or Borrower: 1* Race*

Data Field Name Data Point Name

34 Race of Applicant or Borrower: 2* Race*
35 Race of Applicant or Borrower: 3 Race
36 Race of Applicant or Borrower: 4 Race
37 Race of Applicant or Borrower: 5 Race
38 Race of Applicant or Borrower: Free Form Text Field for American Indian or Alaska Native Enrolled or Principal Tribe Race 39 Race of Applicant or Borrower: Free Form Text Field for Other Asian Race 40 Race of Applicant or Borrower: Free Form Text Field for Other Pacific Islander Race 41 Race of Co-Applicant or Co-Borrower: 1* Race* 42 Race of Co-Applicant or Co-Borrower: 2* Race* 43 Race of Co-Applicant or Co-Borrower: 3 Race 44 Race of Co-Applicant or Co-Borrower: 4 Race 45 Race of Co-Applicant or Co-Borrower: 5 Race 46 Race of Co-Applicant or Co-Borrower: Free Form Text Field for American Indian or Alaska Native Enrolled or Principal Tribe Race 47 Race of Co-Applicant or Co-Borrower: Free Form Text Field for Other Asian Race 48 Race of Co-Applicant or Co-Borrower: Free Form Text Field for Other Pacific Islander Race 49 Race of Applicant or Borrower Collected on the Basis of Visual Observation or Surname Race 50 Race of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname Race 51 Sex of Applicant or Borrower* Sex* 52 Sex of Co-Applicant or Co-Borrower* Sex* 53 Sex of Applicant or Borrower Collected on the Basis of Visual Observation or Surname Sex 54 Sex of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname Sex 55 Age of Applicant or Borrower* Age* 56 Age of Co-Applicant or Co-Borrower* Age* 57 Income* Income* 58 Type of Purchaser Type of Purchaser 59 Rate Spread Rate Spread 60 HOEPA Status HOEPA Status 61 Lien Status* Lien Status* 62 Credit Score of Applicant or Borrower Credit Score 63 Credit Score of Co-Applicant or Co-Borrower Credit Score

Data Field Name Data Point Name

64 Applicant or Borrower, Name and Version of Credit Scoring Model Credit Score 65 Applicant or Borrower, Name and Version of Credit Scoring Model: Conditional Free Form Text Field For Code 8 Credit Score 66 Co-Applicant or Co-Borrower, Name and Version of Credit Scoring Model Credit Score 67 Co-Applicant or Co-Borrower, Name and Version of Credit Scoring Model: Conditional Free Form Text Field For Code 8 Credit Score 68 Reason for Denial: 1 Reason for Denial 69 Reason for Denial: 2 Reason for Denial 70 Reason for Denial: 3 Reason for Denial 71 Reason for Denial: 4 Reason for Denial 72 Reason for Denial: Conditional Free Form Text Field for Code 9 Reason for Denial 73 Total Loan Costs Total Loan Costs or Total Points and Fees 74 Total Points and Fees Total Loan Costs or Total Points and Fees 75 Origination Charges Origination Charges 76 Discount Points Discount Points 77 Lender Credits Lender Credits 78 Interest Rate Interest Rate 79 Prepayment Penalty Term Prepayment Penalty Term 80 Debt-to-Income Ratio Debt-to-Income Ratio 81 Combined Loan-To-Value Ratio Combined Loan-To-Value Ratio 82 Loan Term Loan Term 83 Introductory Rate Period Introductory Rate Period 84 Balloon Payment Non-Amortizing Features 85 Interest-Only Payments Non-Amortizing Features 86 Negative Amortization Non-Amortizing Features 87 Other Non-Amortizing Features Non-Amortizing Features 88 Property Value Property Value 89 Manufactured Home Secured Property Type Manufactured Home Secured Property Type 90 Manufactured Home Land Property Interest Manufactured Home Land Property Interest 91 Total Units* Total Units* 92 Multifamily Affordable Units Multifamily Affordable Units

Data Field Name Data Point Name

93 Submission of Application Application Channel 94 Initially Payable to Your Institution Application Channel 95 Mortgage Loan Originator NMLSR Identifier Mortgage Loan Originator NMLSR Identifier 96 Automated Underwriting System: 1 Automated Underwriting System 97 Automated Underwriting System: 2 Automated Underwriting System 98 Automated Underwriting System: 3 Automated Underwriting System 99 Automated Underwriting System: 4 Automated Underwriting System 100 Automated Underwriting System: 5 Automated Underwriting System 101 Automated Underwriting System: Conditional Free Form Text Field for Code 5 Automated Underwriting System 102 Automated Underwriting System Result: 1 Automated Underwriting System 103 Automated Underwriting System Result: 2 Automated Underwriting System 104 Automated Underwriting System Result: 3 Automated Underwriting System 105 Automated Underwriting System Result: 4 Automated Underwriting System 106 Automated Underwriting System Result: 5 Automated Underwriting System 107 Automated Underwriting System Result: Conditional Free Form Text Field for Code 16 Automated Underwriting System 108 Reverse Mortgage Reverse Mortgage 109 Open-End Line of Credit Open-End Line of Credit 110 Business or Commercial Purpose Business or Commercial Purpose

Table 2
A

B
Designated Key HMDA Data Fields for financial institutions not eligible for an EGRRCPA partial exemption from HMDA data collection, recording, and reporting requirements C Designated Key HMDA Data Fields for financial institutions that are eligible for an EGRRCPA partial exemption from HMDA data collection, recording, and reporting requirements 3 Universal Loan Identifier (ULI) 4 Application Date Application Date 5 Loan Type Loan Type 6 Loan Purpose Loan Purpose 9 Occupancy Type Occupancy Type 10 Loan Amount Loan Amount 11 Action Taken Action Taken 12 Action Taken Date Action Taken Date 18 Census Tract Census Tract 19 Ethnicity of Applicant or Borrower: 1 Ethnicity of Applicant or Borrower: 1 25 Ethnicity of Co-Applicant or Co-Borrower: 1 Ethnicity of Co-Applicant or Co-Borrower: 1 33 Race of Applicant or Borrower: 1 Race of Applicant or Borrower: 1 34 Race of Applicant or Borrower: 2 Race of Applicant or Borrower: 2 41 Race of Co-Applicant or Co-Borrower: 1 Race of Co-Applicant or Co-Borrower: 1 42 Race of Co-Applicant or Co-Borrower: 2 Race of Co-Applicant or Co-Borrower: 2 51 Sex of Applicant or Borrower Sex of Applicant or Borrower 52 Sex of Co-Applicant or Co-Borrower Sex of Co-Applicant or Co-Borrower 55 Age of Applicant or Borrower Age of Applicant or Borrower 56 Age of Co-Applicant or Co-Borrower Age of Co-Applicant or Co-Borrower 57 Income Income 61 Lien Status Lien Status 62 Credit Score of Applicant or Borrower 63 Credit Score of Co-Applicant or Co-Borrower 75 Origination Charges 76 Discount Points 77 Lender Credits 78 Interest Rate 80 Debt-to-Income Ratio 81 Combined Loan-To-Value Ratio 82 Loan Term 88 Property Value 89 Manufactured Home Secured Property Type 91 Total Units Total Units 102 Automated Underwriting System Result: 1 108 Reverse Mortgage 109 Open-End Line of Credit 110 Business or Commercial Purpose