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.
