Home Mortgage Disclosure Act

Congress believed that some financial institutions had contributed to the decline of some geographic areas by their failure to provide adequate home financing to qualified applicants on reasonable terms and conditions.

Thus, one purpose of HMDA and Regulation C is to provide the public with information that will help show whether financial institutions are serving the housing credit needs of the neighborhoods and communities in which they are located.

Finally, the FIRREA amendments of 1989 require the collection and disclosure of data about applicant and borrower characteristics to assist in identifying possible discriminatory lending patterns and enforcing antidiscrimination statutes.

[4] Additional information on institutional and transactional coverage for HMDA data collection years 2017 and onward can be found on the CFPB's regulation implementation page.

Some changes include: On behalf of the FFIEC, the CFPB maintains a HMDA compliance guide that is publicly available and contains information on how and what to report in the data collection.

HMDA datasets are published annually and include the Loan Application Register (LAR), Transmittal Sheet (TS), and Panel.

The Panel is a compilation of regulatory data related to an institution that is used to profile HMDA reporters by peer group, such as by asset size, or by depository status and provide identifiers that link to other datasets, such as the CRA and the National Information Center.

In all cases of possible discrimination, the basic regulatory inquiry revolves around whether a protected class of persons being denied a loan or offered different terms for reasons other than objectively acceptable characteristics (e.g. income, collateral).

Again, the key litmus test is whether the objective characteristic being used to lower or raise the mortgage rate for a given group is substantive in its own right with respect to the risk or profitability of the potential loan, rather than mere a proxy for racial discrimination.