Introducing The New And Revised Data Points In HMDA

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CONS UMER FINANCIAL P ROTECTION BUREAU AUGUS T 2019Introducing New andRevised Data Points inHMDAInitial Observations from New and Revised Data Points in 2018HMDA0

This is another in an occasional series of publications from the Consumer Financial ProtectionBureau’s Office of Research. These publications are intended to further the Bureau’s objective ofproviding an evidence-based perspective on consumer financial markets, consumer behavior,and regulations to inform the public discourse. See 12 U.S.C. §5493(b).11T h is r eport was prepared by Feng Liu, Jason Dietrich, Young Jo, Akaki Skhirtladze, Misha Davies, and CorinneCa n dilis.1

Table of contentsTable of contents .21.Introduction .42.Open-end and Reverse Mortgage Flags.103.2.1Open-end Line of Credit Flag . 102.2Reverse Mortgage Flag .112.3Separating Reverse Mortgages from Forward Mortgages and Lines ofCredit . 12Expanded and Revised Demographic Information .163.1Age . 163.2Expanded Race and Ethnicity Fields and Reporting of DisaggregatedCategories. 183.3Visual Observation of Race, Ethnicity and Sex. 224.Property Type .245.Loan Purpose and Characteristics .256.25.1Business or Commercial Purpose Flag. 255.2Loan Purpose . 275.3Loan Term . 305.4Introductory Rate Period. 325.5Non-Amortizing Features. 345.6Prepayment Penalty Term . 365.7Submission of Application and Initially Payable Flags . 38Applicant/Borrower and Property Characteristics .42

7.8.6.1Occupancy Type . 426.2Property Value . 456.3Loan Amount and Conforming Loan Flag. 466.4Credit Score. 476.5CLTV.546.6DTI. 586.7Manufactured Home Secured Property Type . 616.8Manufactured Home Land Property Interest . 636.9Number of Affordable Units for Multifamily Loan . 65Pricing Outcomes and Components .667.1Interest Rate. 667.2Rate Spread . 717.3Total Loan Costs or Total Points and Fees . 747.4Origination Charges. 767.5Discount Points and Lender Credits . 79Miscellaneous .84Appendix A:Tables.86Appendix B:Figures .2513

1. IntroductionThe Home Mortgage Disclosure Act (HMDA) is a data collection, reporting, and disclosurestatute that was enacted in 1975. HMDA data are used to assist in determining whether financialinstitutions are serving the housing needs of their local communities; facilitate public entities’distribution of funds to local communities to attract private investment; and help identifypossible discriminatory lending patterns. 2 Institutions covered by HMDA are required toannually collect and report specified information about each mortgage application acted uponand mortgage purchased during the prior calendar year. 3 The data include the disposition ofeach application for mortgage credit; the type, purpose, and characteristics of each homemortgage application or purchased loan; the census-tract designations of the properties; loanpricing information; demographic and other information about loan applicants, including theirrace, ethnicity, sex, and income; and information about loan sales. 4In the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (DFA), Congressamended HMDA to require the reporting of 13 new data points (Mandated Data Points): Age;Total Points and Fees; Rate Spread for all loans; Prepayment Penalty Term; Property Value;Introductory Rate Period; Non-Amortizing Features; Loan Term; Application Channel; CreditScore; Mortgage Loan Originator Identifier; Universal Loan Identifier; and Property Address.5The DFA also granted the Bureau authority to use its discretion to require reporting ofadditional data points.In 2015, the Bureau issued a rule (2015 HMDA Rule) amending Regulation C, HMDA’simplementing regulation, to include new data points. The 2015 HMDA Rule included theMandated Data Points discussed above. The 2015 HMDA Rule also included 14 additional datapoints the Bureau issued pursuant to its discretionary authority under the DFA (DiscretionaryData Points): Origination Charges; Discount Points; Lender Credits; Mandatorily ReportedReasons for Denial; Interest Rate; Debt-to-Income Ratio; Combined Loan-to-Value Ratio;Manufactured Home Secured Property Type; Manufactured Home Land Property Interest;2For a brief history of HMDA , see Federal Financial Institutions Ex amination Council, “History of HMDA,” availablea t www.ffiec.gov /hmda/history2.htm.3T h e 2018 HMDA data, which are the subject of t his Da ta Point article, cover m ortgage a pplications a cted upon andm ortgages purchased during calendar year 2018.4See h t tps://s3.amazonaws.com /cfpb-hmda-public/prod/help/2018-hmda-fig.pdf for a full list of it ems reportedu n der HMDA for 2018.5W ith r espect to t he last t hree listed data points, the DFA states that these shall be reported “as t he Bureau maydet ermine t o be a ppropriate.”4

Multifamily Affordable Units; Automated Underwriting System; Reverse Mortgage Flag; OpenEnd Line of Credit Flag; and Business or Commercial Purpose Flag.The 2015 HMDA Rule also made revisions to several preexisting data points. Among otherchanges, the 2015 HMDA Rule replaced Property Type with Construction Type and Total Units,added two enumerations (“cash-out refinance” and “other purpose”) to Loan Purpose, and splitthe “non-owner occupied” category of Occupancy Type into “second residence” and “investmentproperty.” In addition, under the 2015 HMDA Rule, applicants have the option to self-identifytheir race/ethnicity in disaggregated sub-categories (for example, Indian or Chinese are subcategories under Asian) and financial institutions must report such detail, where applicable.Financial institutions must also report, where applicable, whether the race, ethnicity, and sex ofapplicants were collected based on visual observation or surname.Finally, the 2015 HMDA Rule made changes in Regulation C’s coverage requirements. First,reporting of open-end lines of credit became mandatory for reporters that meet certain loanvolume thresholds. Second, the transactional-coverage definition eliminated the previousrequirement to report unsecured loans made for home improvement purposes and now requiresreporting of consumer purpose-loans secured by a dwelling even if not made for one of thepreviously-enumerated purposes.In May 2017, Congress passed the Economic Growth, Regulatory Relief, and ConsumerProtection Act (EGRRCPA) that granted certain HMDA reporters partial exemptions fromHMDA reporting. Under the partial exemptions, these institutions are not required to report anyof the Mandated Data Points other than age and are not required to report any of theDiscretionary Data Points for eligible transactions. Specifically, HMDA reporters that areinsured depository institutions or insured credit unions and that originated fewer than 500closed-end mortgages in each of the two preceding years qualify for this partial exemption withrespect to reporting their closed-end transactions. HMDA reporters that are insured depositoryinstitutions or insured credit unions that originated fewer than 500 open-end lines of credit ineach of the two preceding years also qualify for this partial exemption with respect to reportingtheir open-end transactions. The insured depository institutions must also not have receivedcertain less than satisfactory examination ratings under the Community Reinvestment Act of1977 (CRA) ratings to qualify for the partial exemptions. The Bureau issued an interpretive rule5

in 2018 to clarify which institutions and which data points are covered by the partialexemption. 6As a result of all these changes, the HMDA data collected in 2018 and reported in 2019 differsignificantly from the HMDA data of previous years both in terms of the applications and loansreported and the data points required with respect to those applications and loans. The FilingInstructions Guide (FIG) for HMDA Data Collected in 2018provides specifications for the newdata points, some of which are reported under multiple data fields. 7With respect to the public disclosure of HMDA data, in the 2015 HMDA Rule the Bureauinterpreted HMDA, as amended by the DFA, to require that the Bureau use a balancing test todetermine whether and how HMDA data should be modified prior to its disclosure to protectapplicant and borrower privacy while also fulfilling HMDA’s public disclosure purposes. InDecember 2018, the Bureau issued final policy guidance (Policy Guidance) describingmodifications the Bureau intended to apply to the HMDA data before the Bureau, on behalf ofthe FFIEC, makes the data available to the public on the loan level. 8 The Bureau has announcedthat it intends to address these privacy and disclosure issues through a legislative rulemaking,which will provide the Bureau with an opportunity to reconsider the Policy Guidance followingnotice and comment.In accordance with this Policy Guidance, the following data fields are excluded from the 2018public loan-level HMDA data: Universal-Loan-Identifier or Non-Universal-Loan-Identifier;Application Date; Action Taken Date; Property Address; Credit Score Relied On in Making theCredit Decision; Mortgage Loan Originator Nationwide Mortgage Licensing System and Registry(NMLSR) identifier; Result Generated by the Automated Underwriting System; Free-form TextFields for Race, Ethnicity, Name and Version of Credit Scoring Model, and Reason for Denial;and Name of the Automated Underwriting System. The Bureau also modified the public loanlevel 2018 HMDA data to reduce the precision of most of the values reported for the following:Loan Amount; Age; Debt-to-Income Ratio; Property Value; Total Units; and MultifamilyAffordable Units.6In pa rticular, t he interpretive rule clarifies that Den ial Reasons -- w hich had been an opt ional data point and wasm a de m andatory by the 2015 HMDA Rule -- r ev erts to an opt ional data point for partially-exem pt transactions andt h at institutions are n ot required to r eport Rate Spread -- w hich previously had been r equired with r espect to certainloa n s -- w ith r espect to any partially exempt transactions.7A v ailable at https://s3.amazonaws.com /cfpb-hmda-public/prod/help/2018-hmda-fig.pdf8 A v ailable ath t tps://files.consumerfinance.gov/f/documents/HMDA Data Disclosure Policy Guidance.Executive Summary.FINA L.1 2212018.pdf6

The goals of this Data Point article are to introduce the new or revised data points in the 2018HMDA data and to provide some initial observations about the nation’s mortgage market in2018 based on those new or revised data points. The information contained in this article is notintended to be in-depth and comprehensive, but rather offered as an initial set of findings fromthese new data. Through this exercise, the Bureau hopes to provide the public with a roadmapfor the new HMDA data, as researchers, government agencies, community groups, financialinstitutions, and others may use this new data for various other purposes.At the same time, the Bureau notes that on May 2, 2019, it issued an Advanced Notice ofProposed Rulemaking (ANPR) seeking public comment, data, and information on the costs andbenefits of collecting and reporting the new Mandated and Discretionary Data Points and otherdata points the 2015 HMDA Rule revised to require additional information. On the same date,the Bureau also issued a Notice of Proposed Rulemaking (NPRM) seeking comment on aproposal to increase the loan volume thresholds that determine, in part, which institutions mustreport HMDA data. 9 The information contained in this article, along with the public datasetitself, may be helpful to stakeholders in providing their comments in response to both the ANPRand NPRM. 1 0As the Bureau has recognized, collecting and reporting the new and revised data points in 2018posed significant systems and operational challenges.1 1 For that reason, the Bureau previouslyannounced that it would not require financial institutions to resubmit their 2018 HMDA dataunless errors were material, thus providing financial institutions an opportunity to focus onidentifying any gaps in their implementation of their HMDA compliance management systemsfor future years. Consequently, while the Bureau has taken customary steps to ensure theaccuracy of the data presented in this article and released to the public, such as excluding datathat likely contained errors, there may be some anomalies and non-material errors in the 2018HMDA data that are less likely to be found in prior or future years’ data submissions.9 See Hom e Mor tgage Disclosure (Regulation C) Da ta Points and Cov erage, 89 FR 2 0049 (May 8, 2019); Hom eMor t gage Disclosure (Regulation C), 84 FR 20972 (May 1 3, 2019).10T h e Bureau n otes that the com ment period has closed with r espect to a provision of t he proposed rule which wouldex t end for two y ears a tem porary increase in the loan volume r eporting threshold for open-end lines of credit whicht h e Bureau adopted in 2017. T he Bureau intends to issue a final rule with respect t o that aspect of the proposal latert h is fall.11See Bu reau of Consumer Fin. Pr ot., “CFPB Issues Public Statem ent On Hom e Mor tgage Disclosure Act Com pliance”(Dec. 21, 2017), https://www.consumerfinance.gov /about-us/newsroom /cfpb-issues-public-statement-hom em ortgage-disclosure-act-com pliance/.7

In addition to this Data Point article and the other Data Point article titled “2018 MortgageMarket Activity and Trends” published concurrently 1 2, the Bureau is also publishing a staticloan-level 2018 HMDA data file that consolidates data from individual reporters.1 3 This data filereflects modifications to the data to protect applicant and borrower privacy. This data file andthe two Data Point articles reflect the data as of August 7th, 2019. Though this staticconsolidated loan-level file will not be changed, the Bureau will separately provide updates tothe consolidated loan-level 2018 HMDA data to reflect any later resubmissions or latesubmissions. Thus, results of analyses using updated consolidated loan-level 2018 data maydiffer from results reported in this Data Point article. However, we expect that updated,consolidated loan-level data would produce substantially similar results.This article uses some non-public HMDA data in its analysis and findings.For exposition purpose, the article groups the new and revised HMDA data points into sevenmajor categories: Open-end and Reverse Mortgage Flags; Expanded or Revised DemographicInformation; Property Type; Loan Purpose and Characteristics; Applicant/Borrower CreditCharacteristics and Property Characteristics; Pricing Outcome and Components; and Others.These groupings, though natural from the perspective of most data users, do not reflect anyregulatory requirements.1 4The remainder of this article is organized as follows: For each grouping, we will discuss eachnew or revised data point. For each data point, we will first explain the definition, basicreporting requirements, and allowable enumeration or values under the 2015 HMDA Rule and2018 FIG. We will also note any modifications applied to the data point before public disclosureof the loan-level 2018 HMDA data. The article then provides some basic observations using thedata point from the 2018 data. Where appropriate, the article will provide context to help datausers better understand the limitations of such data points, especially if one or a few data pointsare to be used in isolation. Although this article is structured to introduce each new or reviseddata point in a specified order, in many instances the interaction of multiple data points areexamined prior to the formal introduction of some of the data points. In such instances, readerscan refer to the formal definition of the not-yet-introduced data points in later sections.1 2A v ailable at arch-reports/cfpb-data-point-2018-m ortgage-m arket-activity-and-trends/1314A v ailable at ational-loan-level-dataset/2018It is a lso possible that different HMDA data users or readers of this article may find different ways of g rouping then ew/revised HMDA data points that are m ore relevant t o them. Again, the grouping in this article is for expositionpu r pose on ly a nd is entirely non-binding.8

Tables and Figures are described in the body of this article and appear in Appendices A and Brespectively.9

2. Open-end and ReverseMortgage Flags2.1 Open-end Line of Credit FlagThe 2015 HMDA Rule changed the reporting of open-end lines of credit (LOC) from optional tomandatory. Specifically, institutions that originated at least 100 open-end LOCs in each of thetwo preceding calendar years and met other reporting criteria would have been required toreport data on open-end LOCs beginning with data collected in 2018 and reported in 2019. In2017, the Bureau temporarily increased the open-end LOC reporting threshold to 500 forcalendar years 2018 and 2019. The 2015 HMDA Rule also added a new data point consisting of aflag for open-end LOCs to distinguish these from closed-end mortgage records. Open-end LOCFlag is one of the Discretionary Data Points as discussed in the introduction section of thisarticle. The open-end LOC flag is among the data points that institutions that qualify for anEGRRCPA partial exemption are not required to report. It has an allowable value of 1 for “openend line of credit,” 2 for “not an open-end line of credit,” and 1111 for “exempt.”In the 2018 HMDA data, 1,029 financial institutions reported about 2.33 millionLoan/Application Register (LAR) records for open-end LOCs. The total number of applicationsfor open-end LOCs is about 2.3 million, including about 1.15 million associated originations forwhich the open-end LOC flag is reported to be 1.Table 2.1.1 lists the top 25 open-end LOC lenders by origination volume in 2018, theirinstitution type, number of open-end applications, number of open-end originations, number ofopen-end purchased loans, assets, and their respective market share in terms of their reportedopen-end originations relative to the total volume of open-end originations in 2018 HMDA data.In total, the top 25 open-end lenders accounted for about 644,000 open-end originations, or56.1 percent of all open-end originations reported under HMDA. All of the top 25 open-endlenders are depository institutions or credit unions with the exception of one non-depositoryinstitution that specializes in reverse mortgages.Table 2.1.2 breaks down the open-end LOC reporters by size category. Overall, 956 HMDAreporters reported at least one open-end LOC origination. Specifically, 487 reporters originatedfewer than 100 open-end LOC originations, 61 reporters originated between 100 and 199, and10

101 reporters originated between 200 and 499 open-end LOCs. 1 5 Together, the reporters with anopen-end origination volume below 500 accounted for about 52,000 originations, or 4.5 percentof all reported open-end originations.2.2 Reverse Mortgage FlagThe 2015 HMDA Rule added a data point that flags whether the loan or application is for areverse mortgage. Reverse Mortgage Flag is one of the Discretionary Data Points as discussed inthe introduction section of this article. The reverse mortgage flag is one of the data points thatinstitutions that qualify for the EGRRCPA partial exemption are not required to report. It has anallowable value of 1 for “reverse mortgage,” 2 for “not a reverse mortgage,” and 1111 for“exempt.”In the 2018 HMDA data, 168 financial institutions reported approximately 90,300 reversemortgage LAR records. The total number of applications for reverse mortgages is about 57,500,including approximately 33,000 reverse mortgage originations with a flag value of 1.Table 2.2.1 lists the top 10 reverse mortgage lenders by origination volume in 2018, theirinstitution type, applications, originations, purchased loans, assets, and their market share interms of their reported reverse mortgage originations relative to the total volume of reversemortgage originations in 2018 HMDA data. In total, the top 10 reverse mortgage lendersaccounted for approximately 27,900 reverse mortgage originations, or 84.5 percent of allreverse mortgage originations reported under HMDA.Table 2.2.2 breaks down the reverse mortgage reporters by size category. Overall, for 2018, 126HMDA reporters reported at least one reverse mortgage origination, and 103 reported fewerthan 100 reverse mortgage originations.15Not e t hat t he t emporary HMDA open-end r eporting threshold of 5 00 originations is based on t he originationv olumes for the two years preceding the HMDA activity year. Specifically for the 2018 HMDA data t hat are collectedin 2 018 and reported in 2019, a lender would be required t o report its open-end lending activity if it originated at least5 0 0 open-end LOC in both 2016 and 2017, assuming it a lso met other reporting criteria. Therefore, it is possible t hatsom e lenders with open-end LOC origination v olume exceeding 500 in both 2016 and 2017 or iginated fewer t han 500open -end LOC in 2018, but were n evertheless required t o report the 2018 data under the HMDA r eportingr equ irements. On the other hand, it is a lso possible that som e of the reporters opted t o report their open-end lendinga ct ivities ev en though they were not required t o report.11

2.3 Separating Reverse Mortgages fromForward Mortgages and Lines of CreditThe 2015 HMDA Rule does not set a separate reporting threshold for reporting reversemortgages. Table 2.3.1 cross-tabulates the reported values for the Reverse Mortgage Flag againstthe reported values of Open-end Flag for the 2018 HMDA data. As shown in the table, about75.2 percent of reverse mortgage originations are structured as open-end LOCs and 24.8 percentare closed-end. Similarly, about 72.2 percent of all reverse mortgage LAR records are structuredas open-end and 27.8 percent are closed-end.Reverse mortgages are different from traditional forward mortgages and LOCs in terms of theirintended purpose, characteristics, and customer base. Therefore, the remainder of this articleseparates reverse mortgages from other forward transactions by grouping all LAR records intothree transaction types: closed-end mortgages excluding reverse mortgage, open-end LOCsexcluding reverse mortgages, and reverse mortgages. The closed-end mortgages excludingreverse mortgages are transactions with an open-end LOC flag reported as 2 (not an open-endLOC) and reverse mortgage flag reported as 2 (not a reverse mortgage). The open-end LOCsexcluding reverse mortgages are transactions with an open-end LOC flag reported as 1 (openend LOC) and reverse mortgage flag reported as 2 (not a reverse mortgage). Reverse mortgagesare transactions with a reverse mortgage flag reported as 1 (reverse mortgage).Open-end LOCs secured by dwellings (excluding reverse mortgages) are commonly known ashome equity lines of credit, or HELOCs. Due to the partial exemption granted under theEGRRCPA, about 403,000 LAR records have either the open-end flag or reverse mortgage flagreported as 1111 (Exempt). For most of the discussion regarding transaction types, we have notincluded those records reported as exempt. They account for only a small fraction of all LARrecords.Table 2.3.2 shows the distribution of transaction type by action taken for closed-end mortgages,HELOCs, and reverse mortgages of LAR records.1 616For br evity, we have rem oved the phrase “excluding r everse m ortgage” from “ closed-end mortgage” and “ open-endLOCs” from this point on . Unless it is specifically stated otherwise, for the rest of t he article, “ closed-end mortgages”r efer to “ closed-end mortgages excluding reverse mortgages” and “ HELOCs” refer to “ open-end LOCs excludingr ev erse m ortgages.”12

The denial rate for HELOC applications is significantly higher than for closed-end mortgages.Excluding applications that are withdrawn or closed for incompleteness, the denial rate forHELOC applications in the 2018 HMDA data was about 42 percent. In comparison, the denialrate for closed-end mortgage applications was 20.1 percent.1 7About 36.3 percent of the reverse mortgage records reported under HMDA are purchased loans,and none of the reverse mortgage records have a code indicating a preapproval request deniedor preapproval request approved but not accepted. In total, there were about 33,000 reversemortgage originations reported. The denial rate of reverse mortgage applications, excludingapplications that are withdrawn or closed for incompleteness, was about 21.1 percent.Table 2.3.3 shows the distribution of closed-end, HELOC, and reverse mortgage originations byrace/ethnicity, neighborhood income, and geography.1 8The table indicates that HELOCborrowers are more likely than closed-end borrowers to be non-Hispanic White, be in highincome tracts, and live in metropolitan areas. In particular, 71.1 percent of HELOC borrowersare non-Hispanic Whites, compared to 61.0 percent for closed-end mortgage borrowers.Approximately 11.6 percent of HELOC borrowers live in a low- or moderate-income censustracts, compared to 17.8 percent of closed-end borrowers. In addition, 47 percent of HELOCborrowers live in high-income tracts, compared to 37.3 percent of closed-end borrowers. Aslightly higher percentage of HELOC borrowers live in a metropolitan statistical area (91.3percent), compared to 89.4 percent of closed-end borrowers. Only 2.9 percent of HELOCborrowers are located in rural areas, slightly lower than that of closed-end borrowers (3.8percent). 1 9Non-Hispanic Whites make up a higher percentage of 2018 reverse mortgage borrowers (76.6percent) than they do of closed-end or HELOC borrowers. The share of reverse mortgages in17On ly 0 .3 percent of all 2.26 million HELOC records r eported under HMDA are purchased loans, and none of theHELOC r ecords contain an indication for a preapproval r equest denied or preapprov al request a pprov ed but nota ccepted.1 8 Not e t hat in Table 2.3.3 the sums of t otal or iginations across the n eighborhood incom e rows and the sums a crossg eog raphy rows are slightly sm aller t han the sums a cross “borrower race and ethnicity” r ows, because there are asm all percentage of r ecords that did not r eport census tracts and h ence for which we could n ot assign then eighborhood incom e category. Similarly, there are a sm all percentage of records that did not report county or st atecode, therefore, we could not determine whether they are in a m etropolitan statistical area, micropolitan st atisticala r ea, or rural area. Such r ecords are om itted in relevant tabulation accordingly.In g en eral, within this article, total sample size may v ary across t ables because of differences in sample universe andin m issing v alues a cross data points. For more information, see the note section of each t able.19In t h is article, rural areas are defined as areas that are located outside of any m etropolitan statistical area orm icropolitan statistical area.13

low- or moderate-income tracts is higher than for closed-end and for HELOC borrowers. Therural share is also slightly higher for reverse mortgages tha

added two e numerations ( "cash -out r efinance" an d " other p urpose") t o Loan P urpose, an d s plit the "non-owner o ccupied" category o f Occupancy Type i nto " se cond r esidence" a nd " in vestment propert y." In ad dition, un der t he 20 15 H MDA R ule, ap plicants h ave t he o ption t o s elf -identify

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