INTERAGENCY HMDA KEY FIELDS PUBLISHED

The FRB, the FDIC, and the OCC recently issued Designated Key HMDA Data Fields to support the efficient and effective evaluation of financial institutions’ compliance with the HMDA’s requirements. Of 110 data fields, 37 are identified as key fields. In certain circumstances, however, examiners may determine it necessary to review additional HMDA data fields, as appropriate.

Background

The HMDA, which is implemented by Regulation C (12 CFR 1003), requires certain financial institutions to collect, record, and report information about their mortgage lending activity. Amendments to Regulation C (HMDA amendments) establish the data to be collected. To ensure compliance with the HMDA’s requirements, traditionally the FRB, 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 fields considered to be most important to ensuring the integrity of analyses of overall HMDA data.

Separately, the Federal Financial Institutions Examination Council (FFIEC) members issued “FFIEC HMDA Examiner Transaction Testing Guidelines” (guidelines) for the FFIEC members’ examination staff to use in assessing the accuracy of the HMDA data that financial institutions record and report. The guidelines include a data sampling process that involves prioritizing designated data fields for review or reviewing all data fields within a sample. The guidelines themselves, however, do not establish designated key data fields.

In an effort to promote efficiency, coordination, and consistency, the FRB, the FDIC, and the OCC have jointly identified and designated 37 of the HMDA data fields to be collected beginning January 1, 2018, pursuant to the HMDA amendments, as Designated Key HMDA Data Fields. In identifying the Designated Key HMDA Data Fields, the FRB, the FDIC, and the OCC considered a variety of factors, including the 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 Community Reinvestment Act and fair lending requirements. The FRB, 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, to evaluate financial institutions’ compliance with HMDA requirements, FRB, FDIC, and OCC examination staffs will focus on the Designated Key HMDA Data Fields during transaction testing pursuant to the HMDA for data collected on or after January 1, 2018. In certain circumstances, however, consistent with the FFIEC guidelines, such examination staff may determine that it is necessary to review additional HMDA data fields, as appropriate.

As suggested above, proper reporting of HMDA data is important in assessing the accuracy of the HMDA data that financial institutions record and report. Where errors that exceed established thresholds are identified in an institution’s HMDA data, the OCC supervisory office has discretion to require the institution to correct specific errors, without requiring resubmission of the data. The supervisory office may require resubmission of HMDA data when the inaccurate data are indicative of systemic internal control weaknesses that call into question the integrity of the institution’s entire HMDA data report.

All 110 data fields are listed in the table below. Designated Key HMDA Data Fields are shown in italicized bold text.

 

# Data Field Name
1 Record Identifier
2 Legal Entity Identifier (LEI)
3 Universal Loan Identifier (ULI)
4 Application Date
5 Loan Type
6 Loan Purpose
7 Preapproval
8 Construction Method
9 Occupancy Type
10 Loan Amount
11 Action Taken
12 Action Taken Date
13 Street Address
14 City
15 State
16 Zip Code
17 County
18 Census Tract
19 Ethnicity of Applicant or Borrower: 1
20 Ethnicity of Applicant or Borrower: 2
21 Ethnicity of Applicant or Borrower: 3
22 Ethnicity of Applicant or Borrower: 4
23 Ethnicity of Applicant or Borrower: 5
24 Ethnicity of Applicant or Borrower: Free Form Text Field for Other Hispanic or Latino
25 Ethnicity of Co-Applicant or Co-Borrower: 1
26 Ethnicity of Co-Applicant or Co-Borrower: 2
27 Ethnicity of Co-Applicant or Co-Borrower: 3
28 Ethnicity of Co-Applicant or Co-Borrower: 4
29 Ethnicity of Co-Applicant or Co-Borrower: 5
30 Ethnicity of Co-Applicant or Co-Borrower: Free Form Text Field for Other Hispanic or Latino
31 Ethnicity of Applicant or Borrower Collected on the Basis of Visual Observation or Surname
32 Ethnicity of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname
33 Race of Applicant or Borrower: 1
34 Race of Applicant or Borrower: 2
35 Race of Applicant or Borrower: 3
36 Race of Applicant or Borrower: 4
37 Race of Applicant or Borrower: 5
38 Race of Applicant or Borrower: Free Form Text Field for American Indian or Alaska Native Enrolled or Principal Tribe
39 Race of Applicant or Borrower: Free Form Text Field for Other Asian
40 Race of Applicant or Borrower: Free Form Text Field for Other Pacific Islander
41 Race of Co-Applicant or Co-Borrower: 1
42 Race of Co-Applicant or Co-Borrower: 2
43 Race of Co-Applicant or Co-Borrower: 3
44 Race of Co-Applicant or Co-Borrower: 4
45 Race of Co-Applicant or Co-Borrower: 5
46 Race of Co-Applicant or Co-Borrower: Free Form Text Field for American Indian or Alaska Native Enrolled or Principal Tribe
47 Race of Co-Applicant or Co-Borrower: Free Form Text Field for Other Asian
48 Race of Co-Applicant or Co-Borrower: Free Form Text Field for Other Pacific Islander
49 Race of Applicant or Borrower Collected on the Basis of Visual Observation or Surname
50 Race of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname
51 Sex of Applicant or Borrower
52 Sex of Co-Applicant or Co-Borrower
53 Sex of Applicant or Borrower Collected on the Basis of Visual Observation or Surname
54 Sex of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname
55 Age of Applicant or Borrower
56 Age of Co-Applicant or Co-Borrower
57 Income
58 Type of Purchaser
59 Rate Spread
60 HOEPA Status
61 Lien Status
62 Credit Score of Applicant or Borrower
63 Credit Score of Co-Applicant or Co-Borrower
64 Applicant or Borrower, Name and Version of Credit Scoring Model
65 Applicant or Borrower, Name and Version of Credit Scoring Model: Conditional Free Form Text Field For Code 8
66 Co-Applicant or Co-Borrower, Name and Version of Credit Scoring Model
67 Co-Applicant or Co-Borrower, Name and Version of Credit Scoring Model: Conditional Free Form Text Field for Code 8
68 Reason for Denial: 1
69 Reason for Denial: 2
70 Reason for Denial: 3
71 Reason for Denial: 4
72 Reason for Denial: Conditional Free Form Text Field for Code 9
73 Total Loan Costs
74 Total Points and Fees
75 Origination Charges
76 Discount Points
77 Lender Credits
78 Interest Rate
79 Prepayment Penalty Term
80 Debt-to-Income Ratio
81 Combined Loan-To-Value Ratio
82 Loan Term
83 Introductory Rate Period
84 Balloon Payment
85 Interest-Only Payments
86 Negative Amortization
87 Other Non-Amortizing Features
88 Property Value
89 Manufactured Home Secured Property Type
90 Manufactured Home Land Property Interest
91 Total Units
92 Multifamily Affordable Units
93 Submission of Application
94 Initially Payable to Your Institution
95 Mortgage Loan Originator NMLSR Identifier
96 Automated Underwriting System: 1
97 Automated Underwriting System: 2
98 Automated Underwriting System: 3
99 Automated Underwriting System: 4
100 Automated Underwriting System: 5
101 Automated Underwriting System: Conditional Free Form Text Field for Code 5
102 Automated Underwriting System Result: 1
103 Automated Underwriting System Result: 2
104 Automated Underwriting System Result: 3
105 Automated Underwriting System Result: 4
106 Automated Underwriting System Result: 5
107 Automated Underwriting System Result: Conditional Free Form Text Field for Code 16
108 Reverse Mortgage
109 Open-End Line of Credit
110 Business or Commercial Purpose

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