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WBK Industry News - Federal Regulatory Developments

BCFP Releases Final Policy Guidance on Public Disclosure of HMDA Data

On December 21, 2018, the BCFP released final policy guidance describing the loan-level HMDA data it intends to make publicly available beginning in 2019, including modifications to be applied to the data to protect consumers’ privacy.  The guidance applies to HMDA data collected by financial institutions beginning in 2018.

According to the guidance, public loan-level HMDA data will exclude the following information:

  • universal loan identifier or non-universal loan identifier;
  • date the application was received or the date shown on the application form;
  • date of action taken on a covered loan or application;
  • address of the property securing or proposed to secure the covered loan;
  • credit score or scores relied on in making the credit decision;
  • unique identifier assigned by the NMLSR for the mortgage loan originator;
  • result generated by the automated underwriting system used to evaluate the application; and
  • free-form text fields used to report applicant or borrower race and ethnicity, name and version of the credit scoring model used, principal reason or reasons the application was denied, and automated underwriting system name.

Additionally, public loan-level HMDA data for the following fields will be modified to reduce the precision of most of the reported values:

  • loan amount or amount applied for will be disclosed as the midpoint for the $10,000 interval into which the reported value falls, along with an indication of whether the reported value exceeds the applicable dollar amount limitation on the original principal obligation in effect at the time of application or origination;
  • age of applicant or borrower will be reported in bin values with bottom-code reported values under 35, top-code reported values over 74, and an indication of whether the reported value is 62 or higher;
  • ratio of the applicant’s or borrower’s total monthly debt to the total monthly income relied on in making the credit decision will be reported in bin values with bottom-code reported values under 20% and top-code reported values of 60% or higher, except that values greater than or equal to 36% and less than 50% will be reported without modification;
  • value of property securing or proposed to secure the covered loan will be disclosed as the midpoint for the $10,000 interval into which the reported value falls;
  • number of individual dwelling units related to the property securing or proposed to secure the covered loan will be reported in bin values in ranges of 5 to 24, 25 to 49, 50 to 99, 100 to 149, and 150 and over; and
  • number of individual dwelling units related to the property securing or proposed to secure the covered loan that are income-restricted pursuant to Federal, State, or local affordable housing programs will be disclosed as a percentage, rounded to the nearest whole number of the value reported for the total number of individual dwelling units related to the property securing the covered loan.

The guidance also states that the BCFP intends to commence a separate rulemaking in the spring of 2019 to identify more definitively the modifications to the HMDA data that the BCFP believes to be appropriate, and to incorporate these modifications into the text of Regulation C.

A copy of the BCFP’s final policy guidance is available here.