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Banking agencies identify key HMDA data fields

The federal banking agencies have issued guidance to financial institutions on the key data fields under the revised Home Mortgage Disclosure Act (HMDA) rules that will be used to test and validate the accuracy and reliability of the HMDA data.

In October 2015, the CFPB adopted significant changes to the HMDA rules that significantly expanded the amount of information that must be collected and reported.  The changes are effective January 1, 2018.

The guidance issued by the federal banking agencies lists 110 data fields under the revised HMDA rules, and identifies 37 of such fields as Designated Key HMDA Data Fields.  Among the new reporting data fields that the agencies identify as key fields are the applicant’s age and credit score, the origination charges, discount points, lender credits, interest rate, debt-to-income ratio, combined loan-to-value ratio, and the automated underwriting system result.

Despite the identification of certain data fields as key fields for examination purposes, examiners nevertheless may determine that additional HMDA data fields need to be examined.

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About this Author

Richard J. Andreano, Jr. , Ballard Spahr Law Frim, Washington DC,  Business and Finance attorney, Mortgage Banking, Consumer Financial Services, Fair Lending

Richard J. Andreano, Jr., is the Practice Leader of Ballard Spahr's Mortgage Banking Group. He has devoted 30 years of practice to financial services, mortgage banking, and consumer finance law.

Mr. Andreano advises banks, lenders, brokers, home builders, title companies, real estate professionals, and other settlement providers on regulatory compliance and transactional matters, Federal Housing Administration (FHA) issues, and administrative examinations, enforcement actions and investigations. He also works with litigation counsel on devising strategies for defense of class action...

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