The CFPB has released the public disclosures for HMDA data submitted for calendar year 2017.
HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As the tables are no longer required to be made a part of your CRA Public File, you can also now remove the calendar year 2015 HMDA disclosures from the CRA public file.
The HMDA data is available by going to https://ffiec.cfpb.gov/data‐publication and under “Data Publication,” select “Disclosure Reports.” On the next page, 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., 1 – Applications by Tract, 4‐2 Conventional Purchases by Race, etc.).
At the time of this writing, 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.)
It is important to remember this data is fluid. As changes are made to data (i.e., refilings, corrections) will include any such updated data.
Back in May, the FFIEC issued a press release about the availability of the raw data, along with observations on the 2017 data. For example:
- For 2017, the number of reporting institutions declined by about 13 percent from the previous year to 5,852. Contributing to the decline were Regulation C changes requiring HMDA collection and reporting from depository institutions only if, in each of the two preceding calendar years, they originated at least 25 home purchase loans, including refinancings of home purchase loans, that are not excluded under 12 CFR § 1003.4(d).
- The 2017 data include information on 12.1 million home loan applications, of which 7.3 million resulted in loan originations, and 2.1 million in purchased loans, for a total of more than 14.1 million actions. The data also include information on approximately 481,000 requests for preapprovals for home purchase loans.
- The total number of originated loans of all types and purposes decreased by more than 1 million between 2016 and 2017, or 12.4 percent. Refinance originations decreased by more than 33 percent, and home purchase lending increased by more than 4 percent.
- From 2016 to 2017, the share of first‐lien home purchase loans for 1–4 family, site‐built, owner‐occupied properties made to low‐ and moderate‐income borrowers (those with income of less than 80 percent of area median income) rose slightly from 26.2 percent to 26.3 percent, and the share of refinance loans to low‐ and moderate‐income borrowers increased from 16.9 percent to 22.9 percent.
- In terms of borrower race and ethnicity, the share of home purchase loans for 1–4 family properties made to black borrowers rose from 6.0 percent in 2016 to 6.4 percent in 2017, the share made to Hispanic‐white borrowers remained unchanged at 8.8 percent, and those made to Asian borrowers rose from 5.5 percent to 5.8 percent. From 2016 to 2017, the share of refinance loans made to black borrowers increased from 5.0 percent to 6.0 percent, the share made to Hispanic‐white borrowers increased from 6.2 percent to 6.8 percent, and those made to Asian borrowers fell from 5.5 percent to 4.0 percent.
- In 2017, black and Hispanic‐white applicants experienced higher denial rates for conventional home purchase loans than non‐Hispanic white applicants. The denial rate for Asian applicants is more comparable to the denial rate for nonHispanic white applicants. These relationships are similar to those found in earlier years and, due to the limitations of the HMDA data discussed above, cannot take into account potential differences in risk characteristics across demographic groups.
- The 2017 HMDA data also include information on loan pricing for loans classified as “higher‐priced.” The data on the incidence of higher‐priced lending show that 6.9 percent of first‐lien loans originated in 2017 have APRs that exceed the loan price reporting thresholds, up slightly from about 5.5 percent in 2016.
- As noted above, the HMDA data also identify loans that are covered by HOEPA. For 2017, 3,533 loan originations covered by HOEPA were reported: 1,836 home purchase loans; 764 home improvement loans; and 933 refinance loans.
The disclosure tables for prior years for your institution can still be obtained from the FFIEC website.
So, to recap:
- 2017 HMDA data are available for those institution which filed a LAR.
- Institutions do not have to print or maintain the 2017 disclosure tables at their Bank or as part of their CRA public file.
- Institutions should make sure they have their 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. We have put a sample below.
- The CRA public file should still have the 2016 HMDA disclosure tables until the 2018 calendar year HMDA data is released.
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 Web site (www.consumerfinance.gov/hmda). HMDA data for many other financial institutions are also available at this Web site.
As always, TCA is here to help with all your regulatory questions. Call us at 800‐934‐7347 or email us at [email protected]