WBK Industry - Federal Regulatory Developments

FFIEC Releases 2017 HMDA Data

The Federal Financial Institutions Examinations Council (FFIEC) released the 2017 Home Mortgage Disclosure Act (HMDA) data on mortgage lending transactions at 5,852 financial institutions.

FFIEC also indicated that the HMDA loan-level data that is made available to the public will not remain static.  Instead, the data will be updated on a continuing basis on the ffiec.cfpb.gov site in order to include resubmissions and late submissions.  A static dataset that was used in developing observations about the 2017 data is available here.  Additionally, in late March 2018, Loan/Application Registers (LARs) for every HMDA filer of 2017 data were modified to protect borrower privacy and individual institution LARs are available here.

FFIEC’s Press Release announced the availability of 2017 data and noted, among other things, in the “Understanding the Data” section, that:

HMDA data alone cannot be used to determine whether a lender is complying with fair lending laws. The data do not include many potential determinants of loan application and pricing decisions, such as the applicant’s credit history and debt-to-income ratio, the loan-to-value ratio, and other considerations. Therefore, when regulators conduct fair lending examinations, including ones involving loan pricing, they analyze additional information before reaching a determination about an institution’s compliance with fair lending laws.

FFIEC’s Press Release also discusses some observations derived from the 2017 data. A few examples of those observations include:

  • The share of loans originated in 2017 by independent mortgage lenders was 56.1 percent of first-lien owner-occupied home purchases and 55.8 percent of refinance loans. This represented a sharp increase and it was the first year since 1995 that the majority of such loans was made by independent mortgage companies.
  • FHA share of purchase loans for 1-4 family properties declined in 2017 to 22.6 percent, down from 25 percent in 2017. VA guaranteed share of such loans was steady at about 10 percent.  All government-backed share of such purchase loans was 36.3 percent, a slight decline from 2016.  FHA refinance loans for site-built owner-occupied properties increased slightly while VA loan share of refinances for the same type of property refinances decreased.
  • Overall, originated loans of all types decreased by more than 1 million from 2016 to 2017 or about 12.4 percent. Refinance dropped by 33 percent while home purchased loans increased by more than 4 percent.

Other observations relate to those involving race and ethnicity, low-and moderate-income borrowers, race disparities in denials, higher-priced loans, and statistics for many diverse categories.