-
How Well do You Really Know Your HMDA Peers?
Questionable HMDA annual income values can compromise the integrity of fair lending and Community Reinvestment Act (CRA) analysis. This field seems straightforward, right? The lender reports the “gross annual income relied on in making the credit decision”. The lender should “round all dollar amounts to the nearest thousand”. The 2020 Filing Instruction Guide (FIG) also…
-
What the 2019 HMDA Data Tells us About Credit Decisioning
All lenders can recite the 5 C’s of credit backward and forward as easily as reciting the ABCs. However, not as easy is determining the risk of loss and deciding whether to accept or not to accept the risk. Lenders must objectively weigh the importance and evaluate the risk of loss using ratios and thresholds. …
-
Differences between regions in the percent of loans eligible for CARES Act
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, and contains provisions to allow borrowers with federally backed mortgages to request temporary loan forbearance for up to 180 days. In addition, the borrowers have the right to apply for an extension of another 180 days of…
-
Data Integrity in 2019 Modified HMDA LARs
Two months ago, I wrote about data quality issues that I had seen in the 2018 public HMDA dataset. It turns out that HMDA data quality issues persist in 2019. LendingPatterns™ quickly revealed income reporting issues in the LAR. As an example, for one lender, the average reported income for a large batch of loans…
-
2019 Refinancing Uptick by the Numbers
The 2019 uptick in refinancings has been well-documented in the media and by mortgage trade organizations. LendingPatterns™ can slice and dice the HMDA data to shed additional light on this increase. In brief, at a high level, I am seeing a 90.2% increase in the dollar volume of refinancing originations, compared to 2018 ($1.203 trilllion…
-
Mortgage Loans: To Sell or Not to Sell
We decided to take a look at lenders that have the option to sell loans as well as portfolio to see what we can learn about their decisioning and selection process. Happily, we have access to LendingPatterns™. The robust peer selection tool allowed us to create a custom peer group of 2,461 lenders that either…
-
How to Avoid HMDA Reporting Pitfalls From Industry Experts
The public’s interpretation of HMDA data depends on lenders’ consistent application of Reg C, and failure to comply with Reg C could bring stiff penalties from regulatory agencies. ComplianceTech is looking out for HMDA filers in their efforts to ensure perfect HMDA submissions. The challenge that you face is two-fold: one is to pass the HMDA…
-
2019 year-in-review in the world of HMDA
Like last year, I want to write another blog to recap the year’s HMDA developments and look ahead to what’s coming in 2020. This year’s blog will summarize three different fronts: 1) data collection, 2) Reg C changes, and 3) disclosure of public data. In each area, I’ll describe the major developments over the last…
-
On the margins of metro areas
This is the third in a series of blogs related to the 2019 demographic changes. The first dealt with changes in metro area median family incomes and the second dealt with tracts that flipped from low/mod to not low/mod, and vice-versa. As discussed, the 2019 demographic file features some reorganization of metro areas affecting counties…
-
Important Takeaways From the 2018 HMDA Data Release
As we enter the fourth quarter of the year and businesses begin forming their strategies for 2020, they need the most up-to-date consumer data to inform their strategies and match their clients’ needs. For financial institutions, there is no better source than the CFPB’s annual HMDA release. Here are some of the major takeaways from…