The Federal Financial Institutions Examination Council (FFIEC) has published data on the 2024 mortgage lending transactions submitted under the Home Mortgage Disclosure Act (HMDA). This release contains several products, such as the 2024 Snapshot National Loan-Level Dataset, the HMDA Dynamic National Loan-Level Dataset, the Aggregate and Disclosure Reports, the One-Year National Loan-Level Dataset for 2023, and the Three-Year National Loan-Level Dataset for 2021. Additionally, a Data Browser Filtering tool is available for users to download customized reports based on the available data.
HMDA is one of the regulations that relates to Fair Lending. HMDA requires reporters to collect key data on home loans. Not all banks are required to file HMDA data; however, these newly released products and tools can benefit all banks in Fair Lending monitoring and reviews.
If your bank is a HMDA reporter, Fair Lending monitoring and reviews are more streamlined, as a significant portion of the consumer loan data is available for analysis using third-party software or simply Excel. Your data can be analyzed to identify the Target and Control groups based on Sex and/or Ethnicity. When monitoring Fair Lending, it is essential to understand how your bank provides credit to consumers within your assessment area; however, it is also beneficial to know how you compare to your Peer Group. A Peer Group is typically similarly sized banks lending in your assessment area. HMDA Reporters obtain this information once they submit their HMDA data each year.
For banks that are not HMDA reporters, these HMDA Data tools can be utilized to compare your Fair Lending monitoring to other banks in your county, state, etc. The HMDA Data Filtering tool provides information on various data points, including Loan Type, Ethnicity, Sex, and Race, among others. The information obtained can give a snapshot of how your bank compares to other banks in your area.
CCI suggests that you forward this information to your Lending and Compliance teams. As always, CCI is happy to help with any compliance-related questions.
Jackie Smith, CRCM