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 |