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Nov 22 -- the Consumer Financial Protection Bureau (Bureau or CFPB) invites comments to OMB by December 30, 2022 for the information collection Home Mortgage Disclosure Act (Regulation C). [Note: Comment period ends 30 days after CFPB submission to OMB on November 30.]

The Home Mortgage Disclosure Act (HMDA) requires certain depository institutions and for-profit, non-depository institutions to collect, report, and disclose data about originations and purchases of mortgage loans. Additionally, these institutions must report mortgage loan applications that do not result in originations (for example, applications that are denied or withdrawn). The Bureau's Regulation C (12 CFR part 1003) implements HMDA. The purpose of the information collection is:

-- To help determine whether financial institutions are serving the housing needs of their communities;
-- To assist public officials in distributing public-sector investment so as to attract private investment to areas where it is needed; and
-- To assist in identifying possible discriminatory lending patterns and enforcing antidiscrimination statutes.

The information collection will also assist the Bureau's examiners (and examiners of other Federal supervisory agencies) in determining whether the financial institutions they supervise comply with applicable provisions of HMDA.

Regulation C requires financial institutions to submit HMDA data in electronic form. The Bureau implemented several operational improvements in the past few years to facilitate this process. For example, the Bureau developed the HMDA Platform, a web-based submission tool that enables financial institutions to upload their HMDA data, review edits, certify data accuracy and submit data for the filing year. The Bureau also improved the points of contact processes for help inquiries. In addition, the Bureau developed a tool that financial institutions with small volumes of HMDA data can use to create an electronic file for submission to the HMDA Platform and streamlined the submission and validation process to make it more efficient.  

The Bureau stated in the final policy guidance it intends to modify the public loan-level HMDA data by excluding certain fields and reducing the provision of the other fields.  The Bureau believes that these modifications will reduce risks to applicant and borrower privacy and appropriately balance them with the benefits of disclosure in light of HMDA’s purposes.  Data not made publicly available are considered confidential under the Bureau’s confidentiality regulations, 12 CFR part 1070 et seq., and the Freedom of Information Act.  Information that is not disclosed is protected from unauthorized disclosure by several data security safeguards, including privacy and security awareness training for each individual with internal access to the system, technical access controls, and breach notification processes and plans.  More information regarding the privacy and security of the HMDA dataset can be found in the current Privacy Impact Assessment published by the Bureau.  
 
Respondents are financial institutions for which the Bureau provides no assurances of confidentiality.  In December 2018, the Bureau issued final policy guidance describing the modifications the Bureau intended to apply to HMDA data reported by financial institutions at the loan level before the data are made available to the public.  The policy guidance applies to HMDA data collected by financial institutions in or after 2018 and made available to the public beginning in 2019.  In the policy guidance, the Bureau stated that it would modify the public loan-level data by excluding certain fields and reduce the precision of other data fields.  In the Bureau’s determination, these modifications to how the Bureau stores and publishes the reported data will reduce risks to applicant and borrower privacy and appropriately balance them with the benefits of disclosure in light of HMDA’s purposes.  

The Bureau will exclude the following from the public loan-level HMDA data:

-- Universal loan identifier or non-universal loan identifier;
-- Application data;
-- Action taken date;
-- Property address;
-- Credit score relied on in making the credit decision;
-- Unique identifier assigned by the Nationwide Mortgage Licensing System and Registry for the mortgage loan originator;
-- Result generated by the automated underwriting system; and
-- Free-form text fields for:  race, ethnicity, name and version of credit scoring model, reason for denial, and name of automated underwriting system fields.

The Bureau will reduce the precision of most of the values reported for the following:

-- Loan amount;
-- Age;
-- Debt-to-income ratio;
-- Property value; and
-- Total units.

HMDA data: https://www.consumerfinance.gov/data-research/hmda/
Home mortgage disclosure reporting requirements (HMDA): https://www.consumerfinance.gov/compliance/compliance-resources/mortgage-resources/hmda-reporting-requirements/
CFPB submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202211-3170-002 Click on IC List for data collection, View Supporting Statement for technical documentation. Submit comments through this site.
FR notice inviting public comment: https://www.federalregister.gov/d/2022-25411
 
For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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