The CFPB has released the public disclosures for HMDA data submitted for calendar year 2018.
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 2016 HMDA disclosures from the CRA public file, so HMDA tables are no longer needed in 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 (ie. 1 – Applications by Tract, 4‐2 Conventional Purchases by Race, etc…)
As with last year, 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 (ie. refilings, corrections) will include any such updated data.
The FFIEC also issued a press release with observations on the 2018 data. For example:
- For 2018, the number of reporting institutions declined by about 2.9 percent from the previous year to 5,683. The 2018 data include information on 12.9 million home loan applications. Among them, 10.3 million were closed‐end, 2.3 million were open‐end, and, for another 378,000 records, pursuant to the EGRRCPA’s partial exemptions, financial institutions did not indicate whether the records were closed‐end or open‐end. A total of 7.7 million applications resulted in loan originations. Among them, 6.3 million were closed‐end mortgage originations, 1.1 million were open‐end line of credit originations, and, pursuant to the EGRRCPA’s partial exemptions, 283,000 were originations for which financial institutions did not indicate whether they were closed‐end or open‐end. The 2018 data include 2.0 million purchased loans, for a total of 15.1 million records. The data also include information on approximately 177,000 requests for preapprovals for home purchase loans.
- The total number of originated loans decreased by about 924,000 between 2017 and 2018, or 12.6 percent. Refinance originations decreased by 23.1 percent from 2.5 million, and home purchase lending increased by 0.3 percent from 4.3 million.
- A total of 2,251 reporters made use of the EGRRCPA’s partial exemptions for at least one of the 26 data points eligible for the exemptions. In all, they account for about 425,000 records and 298,000 originations.
- From 2017 to 2018, the share of home purchase loans for first lien, 1‐4 family, site‐built, owner‐occupied properties (1‐4 family, 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 26.3 percent to 28.1 percent, and the share of refinance loans to low‐ and moderate‐income borrowers for 1‐4 family, owner‐occupied properties increased from 22.9 percent to 30.0 percent.
- In terms of borrower race and ethnicity, the share of home purchase loans for 1‐4 family, owner‐occupied properties made to Black borrowers rose from 6.4 percent in 2017 to 6.7 percent in 2018, the share made to Hispanic‐White borrowers increased slightly from 8.8 percent to 8.9 percent, and those made to Asian borrowers rose from 5.8 percent to 5.9 percent. From 2017 to 2018, the share of refinance loans for 1‐4 family, owner‐occupied properties made to Black borrowers increased from 5.9 percent to 6.2 percent, the share made to Hispanic‐White borrowers remained unchanged at 6.8 percent, and the share made to Asian borrowers fell from 4.0 percent to 3.7 percent.
- In 2018, Black and Hispanic‐White applicants experienced higher denial rates for 1‐4 family, owner‐occupied conventional home purchase loans than non‐Hispanic‐White applicants. The denial rate for Asian applicants is more comparable to the denial rate for non‐Hispanic‐White applicants. These relationships are similar to those found in earlier years and, due to the limitations of the HMDA data mentioned above, cannot take into account all legitimate credit risk considerations for loan approval and loan pricing.
- The share of mortgages originated by nondepository, independent mortgage companies has increased in recent years. In 2018, this group of lenders accounted for 57.2 percent of 1‐4 family, owner‐occupied home‐purchase loans, up from 56.1 percent in 2017. Independent mortgage companies also originated 56.1 percent of 1‐4 family, owner‐occupied refinance loans, an increase from 55.8 percent in 2017.
- The 2018 HMDA data contains a variety of information reported for the first time. For example, the data indicated that approximately 424,000 applications were for commercial purpose loans and approximately 57,000 applications were for reverse mortgages.
- In addition, among the 12.9 million applications reported, 1.3 million included at least one disaggregate racial or ethnic category. The two most commonly reported disaggregate groups were Mexican and Other Hispanic, which were reported by 3.0 percent and 1.5 percent of applicants, respectively. For approximately 6.3 percent of applications, race and ethnicity of the applicant were collected on the basis of visual observation or surname. The percentage was slightly higher for sex at 6.5 percent.
- For the newly‐reported age data point, the two most commonly reported age groups for applicants were 35‐44 and 45‐54, with 22.7 and 22.4 percent of total applications, respectively. Just under 3.0 percent of applicants were under 25 and just under 4.0 percent of applicants were over 74.
- Debt‐to‐income ratio (DTI) was reported for 75.3 percent of total applications. Approximately 45.1 percent of applications had DTIs between 36.0 percent and 50 percent, with 7.0 percent of applications with less than 20 percent, and 7.1 percent with greater than 60 percent.
- The 2018 HMDA also contains additional pricing information. For example, the median total loan costs for originated closed‐end loans was $3,949. For about 42.5 percent of originated closed‐end loans, borrowers paid no discount points and received no lender credits. The median interest rate for these originated loans was 4.8 percent. The median interest rate for originated open‐end lines of credit excluding reverse mortgages was 5.0 percent.
The disclosure tables for 2016 and earlier for your institution can still be obtained from the FFIEC website at https://www.ffiec.gov/hmdaadwebreport/diswelcome.aspx.
So, to recap:
- 2018 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 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 have any remaining HMDA data tables removed.
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]egs.com.