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CRL Comment on HMDA Changes

October 29, 2014
Mortgage Lending
Research

On October 29, the Center for Responsible Lending joined a coalition of consumer and civil rights organization to comment on the proposed changes to the Home Mortgage Disclosure Act (HMDA) reporting requirements.

Jointly, the groups applauded the utility and growth of the HMDA – which was created as a legislative response to combat urban disinvestment and the practice of redlining. HMDA requires that mortgage lenders report specific information about the loan practices every year – and that information is publicly disclosed. This information has been a critical tool for researchers, community activities, and legislators tracking lending disparities and inequality in the housing marketplace.

The groups supported changes in the HMDA reporting requirements – specifically the move to expand the HMDA data to include new data points; at the same time, the groups encouraged the CFPB to take a step further and modify the structure and reporting requirements while also adding even more data points. The specific recommendations can be found in the full text of the comment.

From the comment:

  1. We support many of the specific changes outlined in the proposal. Specifically, the proposed changes to the definitions of covered institutions and transactions as well as the addition of the proposed new fields would improve the usefulness and quality of the HMDA data. This, in turn, would allow for greater variety and higher quality of analyses to be performed on the data.
  2. We suggest that the CFPB collect five additional variables and make modifications to the way that other variables are collected. Doing so would enhance the ability of researchers, community groups and regulators to assess access to mortgage credit.
  3. HMDA data are a critical public resource and the CFPB should swiftly put in place a process to disseminate as complete a dataset as is prudent to the public. The CFPB should take particular care with the proposed postal address and Unified Loan Identifier fields to protect privacy when making data public.
  4. We suggest that CFPB also examine how to collect information on loan modifications and housing counseling so that researchers and regulators can analyze fair lending patterns in these areas as well.

The groups co-signing this comment include: the Center for American Progress, the Center for Responsible Lending, Consumer Action, Consumer Federation of America, Homeownership Preservation Foundation, National Association of Consumer Advocates, National Association of Neighborhoods, National Coalition for Asian Pacific American Community Development, National Council of La Raza, National Urban League.