On March 7, 2019, the Office of the Comptroller of the Currency (OCC) issued a bulletin titled “Key data fields for full and partial reporters.” The bulletin is in reference to Regulation C, the Home Mortgage Disclosure Act (HMDA). This agency rescinds the related, preceding OCC bulletin 2017-41. The OCC’s intention is to inform the national banks, federal savings associations, and federal branches and agencies about key data fields that the OCC examiners will test and validate the accuracy of HMDA.
As most HMDA reporting banks are aware, the HMDA rule changed a couple of times in 2018. Not only did the rules change, but clarification was needed for partial filers along the way. The OCC’s bulletin directed field examiners to focus on the following areas for both HMDA reporters and partially exempt HMDA reporters:
- Application date
- Loan type
- Loan purpose
- Occupancy type
- Loan amount
- Action taken
- Action taken date
- Census tract
- Ethnicity of applicant or borrower 1
- Ethnicity of co-applicant or co-borrower 1
- Race of applicant or borrower 1
- Race of applicant or borrower 2
- Race of co-applicant or co-borrower 1
- Race of co-applicant or co-borrower 2
- Sex of applicant or borrower
- Sex of co-applicant or co-borrower
- Age of applicant or borrower
- Age of co-applicant or co-borrower
- Income
- Lien status
- Total units
In addition to the above listed shared data fields, the OCC has directed the field examiners to validate the following data fields for the full HMDA reporters:
- Universal Loan Identifier (ULI)
- Credit score of applicant or borrower
- Credit score of co-applicant or co-borrower
- Origination charges
- Discount points
- Lender credits
- Interest rate
- Debt-to-income ratio
- Combined loan-to-value ratio
- Loan term
- Property value
- Manufactured home secured property type.
- Automated underwriting system result: 1
- Reverse mortgage
- Open-end line of credit
- Business or commercial purpose
The OCC also reiterated within the bulletin that the December 2017 interagency announcement that there is no intention by the OCC to require resubmission of HMDA data for the 2018 HMDA Loan Application Register (LAR), unless “data errors are material.” The OCC also reiterated that it does not intend to assess penalties with respect to errors in data collection for the 2018 HMDA LAR.
In 2018, HMDA compliance was a challenge for most filers. Not only did HMDA greatly expand from the pre-2018 rules, the partial exemption for small filers provided by Senate Bill 2155 also provided less clarity of what fields were reportable. Ultimately, Senate Bill 2155 provided significant and noticeable regulatory relief and clarity for partially exempt filers. The OCC bulletin and interagency statement are also helpful for filers as well since the regulatory bodies are up front with the process and remediating processes and solutions.
