The CFPB has released the public disclosures for HMDA data submitted for calendar year 2020.
HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As a reminder, the tables are no longer required to be made a part of your CRA Public File.
The HMDA data is available by going to this CFPB webpage and under “Data Publication”, select “Disclosure Reports.” On the next page, select the Year and enter in the Institution Name to retrieve the disclosure tables for your Institution. You will then have to select the MSA/MD and then each individual report (i.e., Applications by Tract, Loan Purchases by Tract). The only tables available after 2017 are Applications by Tract or Purchases by Tract.
As with prior years, there does not appear to be an option to download all tables for all tracts in one downloaded file, nor an option to print in a streamlined non-HTML format as in previous years, only to save as a CSV file. (The CSV file is NOT pretty.)
Data on race, ethnicity, sex or income are only available for each institution through the HMDA Data Browser or in the aggregate under MSA/MD Aggregate Reports. Both options provide summary reports and downloadable CSV files.
According to the website, the HMDA Data Browser allows users to filter and download HMDA datasets. Users can select from geographic areas they would like to filter by. Upon selection, they can then download a CSV file that includes this geographic data, along with all 99 public data fields. If a user would like to filter data further, they can select from up to two of 11 available variables. Users can then view an aggregated summary table of the data requested and download a CSV file of the filtered data.
It is important to remember this data is fluid. As changes are made to data (i.e., re-filings, corrections) the reports will include any such updated data.
The FFIEC also issued a Press Release with observations on the 2020 data.
The disclosure tables for 2016 and earlier for your institution can still be obtained from the FFIEC website.
So, to recap:
- 2020 HMDA data is available for those institution which filed a LAR.
- Institutions do not have to print or maintain the disclosure tables for 2017 or beyond at their Bank or as part of their CRA public file.
- Institutions should ensure they have paper notices available on request detailing how a requester can obtain the HMDA data from the CFPB website as required under 12 CFR 1003.5(b)(2), comment 5(b)-1.
- As a reminder, this is not the lobby signage, but a printable notice that must be able to be provided on request. Below is a sample Notice.
|Home Mortgage Disclosure Act Notice The HMDA data about our residential mortgage lending are available online for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, age and income of applicants and borrowers; and information about loan approvals and denials. These data are available online at the Consumer Financial Protection Bureau’s website (www.consumerfinance.gov/hmda). HMDA data for many other financial institutions are also available at this Web site.
As always, TCA is A Better Way to help with all your regulatory questions. Now is the time to update your bank’s Fair Lending analysis. Call us at 800-934-7347 or email us at [email protected].
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