OCC Releases List of Key HMDA Data Points

On March 7, 2019, the Office of the Comptroller of the Currency (OCC) released a bulletin (2019-12) explaining the key HMDA data fields for full and partial HMDA reporters.  In their bulletin, the OCC explains that key data fields have been identified to support the efficient and effective evaluation of banks’ compliance with HMDA requirements. Of the 110 total data fields, 37 have been identified as key fields by the OCC, Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) on an interagency basis. The OCC explains that OCC examiners will typically test and validate these 37 key fields for the banks that are required to collect, record, and report information for all HMDA data fields. For banks that qualify for a partial exemption from the HMDA data collection, recording, and reporting requirements, OCC examiners will typically test and validate 21 of those 37 fields.

HMDA Key Data Fields

The following data fields have been identified as the focus point for future examinations.  The full list of 37 fields apply to full HMDA reporters while the bolded items apply to partially exempt HMDA reporters (small filers):

  • Universal Loan Identifier (ULI)

  • Application Date

  • Loan Type

  • Loan Purpose

  • Occupancy Type

  • Loan Amount

  • Action Taken

  • Action Taken Date

  • Census Tract

  • Ethnicity of Applicant or Borrower: 1

  • Ethnicity of Co-Applicant or Co-Borrower: 1

  • Race of Applicant or Borrower: 1

  • Race of Applicant or Borrower: 2

  • Race of Co-Applicant or Co-Borrower: 1

  • Race of Co-Applicant or Co-Borrower: 2

  • Sex of Applicant or Borrower

  • Sex of Co-Applicant or Co-Borrower

  • Age of Applicant or Borrower

  • Age of Co-Applicant or Co-borrower

  • Income

  • Lien Status

  • Credit Score of Applicant or Borrower

  • Credit Score of Co-Applicant or Co-Borrower

  • Origination Charges

  • Discount Points

  • Lender Credits

  • Interest Rate

  • Debt-to-Income Ratio

  • Combined Loan-To-Value Ratio

  • Loan Term

  • Property Value

  • Manufactured Home Secured Property Type

  • Total Units

  • Automated Underwriting System Result: 1

  • Reverse Mortgage

  • Open-End Line of Credit

  • Business or Commercial Purpose

The Importance of Key HMDA Data Fields Going Forward

The bulletin reiterates prior interagency guidance that examiners do not intend to require HMDA resubmission for HMDA data collected in 2018 and reported in 2019, unless data errors are material.  That said, this Bulletin from the OCC should come as a warning for HMDA reporters who are now collecting data for 2019, which is beyond the time period of the initial compliance statement made regarding not requiring resubmissions.  Therefore, this OCC bulletin should be used as a reminder to ensure that, at least, that information found in the identified key data fields is being monitored and checked for accuracy.

While it is often difficult to see the future when it comes to compliance, it appears evident that examiners will be honing in on 21 fields for institutions who qualify for the partial exemption and 37 fields for full HMDA reporters.

The full OCC Bulletin 2019-12 can be found here.  

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