Category: HMDA 2019

  • 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…

  • 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…