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FDIC Financial Institution Letters › FDIC Releases Interagency Designated Key HMDA Data Fields List

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Financial Institution Letter

FIL-51-2017

October 17, 2017

FDIC Releases Interagency Designated Key HMDA Data Fields List

Summary: The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit

Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) are issuing

designated key Home Mortgage Disclosure Act (HMDA) data fields to support the efficient and

effective evaluation of financial institutions’ compliance with HMDA’s requirements.

Statement of Applicability to Institutions With Total Assets Under $1 Billion: This Financial

Institution Letter applies to all FDIC-supervised institutions subject to HMDA and Regulation C. A

HMDA exemption applies to institutions with assets at or below a threshold specified in Regulation C.

Distribution:

FDIC-Supervised Banks

Highlights:



Amendments to Regulation C effective January 1,

2018, (the HMDA Amendments) establish the data

financial institutions will collect and report

pursuant to HMDA requirements.



The Federal Financial Institutions Examination

Council (FFIEC) issued HMDA Examiner

Transaction Testing Guidelines (the Guidelines)

establishing procedures for examination staff to

use when validating HMDA data.



The Guidelines include a data sampling process

that involves prioritizing designated data fields for

review, or reviewing all data fields within a sample.

However, the Guidelines themselves do not

establish designated key data fields.



To promote efficiency, coordination, and

consistency, the FRB, the FDIC, and the OCC

have jointly identified and Designated Key HMDA

Data Fields, consistent with their traditional

practice of designating key fields considered to be

most important to ensuring the integrity of

analyses of HMDA data.



FDIC compliance examination staff will prioritize

the Designated Key HMDA Data Fields in

reviewing data that is collected by financial

institutions in or after 2018 pursuant to the HMDA

Amendments

and Designated Key HMDA

Data Fields, consistent with their traditional

practice of designating key fields considered to be

most important to ensuring the integrity of

analyses of HMDA data.



FDIC compliance examination staff will prioritize

the Designated Key HMDA Data Fields in

reviewing data that is collected by financial

institutions in or after 2018 pursuant to the HMDA

Amendments.

Suggested Routing:

Chief Executive Officer

Compliance Officer

Related Topics:

Home Mortgage Disclosure Act

Attachment:

Designated Key HMDA Data Fields

Contact:

Tim Kalyvas, Examination Specialist, (202) 898-

7102, tkalyvas@fdic.gov

Monika Jansen, Policy Analyst, 202-898-7060,

mjansen@fdic.gov

Note:

FDIC financial institution letters (FILs) may be

accessed from the FDIC's website at

https://www.fdic.gov/news/news/financial/2017/

To receive FILs electronically, please visit

https://service.govdelivery.com/accounts/USFDIC/s

ubscriber/new.

Paper copies of FDIC financial institution letters

may be obtained through the FDIC's Public

Information Center, 3501 Fairfax Drive, E-1002,

Arlington, VA 22226 (1-877-275-3342 or 703-562-

2200).

Federal Deposit Insurance Corporation

550 17th Street NW, Washington, D.C. 20429-9990

Financial Institution Letter

FIL-51-2017

October 17, 2017

Designated Key HMDA Data Fields

The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit

Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) are

issuing designated key HMDA data fields to support the efficient and effective evaluation of

financial institutions’ compliance with HMDA’s requirements.

The Home Mortgage Disclosure Act (HMDA), which is implemented by Regulation C, 12

C.F.R

ors of the Federal Reserve System (FRB), the Federal Deposit

Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) are

issuing designated key HMDA data fields to support the efficient and effective evaluation of

financial institutions’ compliance with HMDA’s requirements.

The Home Mortgage Disclosure Act (HMDA), which is implemented by Regulation C, 12

C.F.R. 1003, requires certain financial institutions to collect, record, and report information

about their mortgage lending activity.1 Amendments to Regulation C (HMDA

Amendments)2 establish the data to be collected.3 For the purpose of ensuring compliance

with HMDA’s requirements, traditionally the FRB, the FDIC, and the OCC have identified

and focused examination-related testing of HMDA data on certain agency-designated “key

fields.” Key fields are those fields considered to be most important to ensuring the integrity

of analyses of overall HMDA data.

Separately, the Federal Financial Institutions Examination Council (FFIEC) members have

issued FFIEC HMDA Examiner Transaction Testing Guidelines (Guidelines) for the FFIEC

members’ examination staff to use in assessing the accuracy of the HMDA data that financial

institutions record and report.4 The Guidelines include a data sampling process that involves

prioritizing designated data fields for review or reviewing all data fields within a sample.

However, the Guidelines themselves do not establish designated key data fields. In an effort

to promote efficiency, coordination, and consistency, the FRB, FDIC, and OCC have jointly

identified and designated 37 of the HMDA data fields to be collected beginning January 1,

2018, pursuant to the HMDA Amendments, as Designated Key HMDA Data Fields

w or reviewing all data fields within a sample.

However, the Guidelines themselves do not establish designated key data fields. In an effort

to promote efficiency, coordination, and consistency, the FRB, FDIC, and OCC have jointly

identified and designated 37 of the HMDA data fields to be collected beginning January 1,

2018, pursuant to the HMDA Amendments, as Designated Key HMDA Data Fields. In

identifying Designated Key HMDA Data Fields, the FRB, FDIC, and OCC considered a

variety of factors, including HMDA’s requirements, the goal of ensuring the efficiency of

bank examinations, and the effective validation of HMDA data important to evaluating

compliance with the Community Reinvestment Act and fair lending requirements. The FRB,

FDIC, and OCC also took into account the likelihood that a data field would be reported

correctly based on past examination experience.

1 12 U.S.C. 2801 et seq.

2 80 FR 66127 (Oct. 28, 2015), as further amended.

3 Beginning with data collected on or after January 1, 2018, financial institutions subject to HMDA will collect and report

data on covered loans specified in 12 C.F.R. 1003.4(a)(1)-(38) on a loan application register containing 110 “data fields,” as

specified in the FFIEC Filing Instructions Guide (FIG). The FIG is available on the FFIEC webpage or on the Consumer

Financial Protection Bureau (CFPB) webpage.

4 The FFIEC members are the FRB, the FDIC, the OCC, the CFPB, the National Credit Union Administration, and the State

Liaison Committee. The FFIEC members promote compliance with federal consumer protection laws and regulations

through supervisory and outreach programs. Among these laws and regulations is HMDA.

he FFIEC webpage or on the Consumer

Financial Protection Bureau (CFPB) webpage.

4 The FFIEC members are the FRB, the FDIC, the OCC, the CFPB, the National Credit Union Administration, and the State

Liaison Committee. The FFIEC members promote compliance with federal consumer protection laws and regulations

through supervisory and outreach programs. Among these laws and regulations is HMDA.

Accordingly, for the purposes of evaluating financial institutions’ compliance with HMDA

requirements, OCC, FDIC, and FRB examination staffs will focus primary attention on the

Designated Key HMDA Data Fields during transaction testing pursuant to HMDA for data

collected on or after January 1, 2018.5 However, in certain circumstances, consistent with

the FFIEC Guidelines, such examination staff may determine that it is necessary to review

additional HMDA data fields, as appropriate.

All 110 data fields are listed in the table below. Designated Key HMDA Data Fields are

shown in italicized bold text.

# Data Field Name

Data Point Name

Record Identifier – Value is 2

Legal Entity Identifier (LEI)

Universal Loan Identifier (ULI)

Universal Loan Identifier

(ULI)

Application Date

Loan Type

Loan Purpose

Preapproval

Construction Method

Occupancy Type

Loan Amount

Action Taken

Action Taken Date

Street Address

Property Address

City

Property Address

State

Property Location &

Property Address

Zip Code

Property Address

County

Property Location

Census Tract

Property Location

Ethnicity of Applicant or Borrower: 1

Ethnicity

Ethnicity of Applicant or Borrower: 2

Ethnicity

Ethnicity of Applicant or Borrower: 3

Ethnicity

Ethnicity of Applicant or Borrower: 4

Ethnicity

Ethnicity of Applicant or Borrower: 5

Ethnicity

on &

Property Address

Zip Code

Property Address

County

Property Location

Census Tract

Property Location

Ethnicity of Applicant or Borrower: 1

Ethnicity

Ethnicity of Applicant or Borrower: 2

Ethnicity

Ethnicity of Applicant or Borrower: 3

Ethnicity

Ethnicity of Applicant or Borrower: 4

Ethnicity

Ethnicity of Applicant or Borrower: 5

Ethnicity

Ethnicity of Applicant or Borrower: Conditional Free

Form Text Field for Code 14

Ethnicity

Ethnicity of Co-Applicant or Co-Borrower: 1

Ethnicity

Ethnicity of Co-Applicant or Co-Borrower: 2

Ethnicity

Ethnicity of Co-Applicant or Co-Borrower: 3

Ethnicity

5 Each agency shall operate in accordance with its supervisory authority.

# Data Field Name

Data Point Name

Ethnicity of Co-Applicant or Co-Borrower: 4

Ethnicity

Ethnicity of Co-Applicant or Co-Borrower: 5

Ethnicity

Ethnicity of Co-Applicant or Co-Borrower: Conditional

Free Form Text Field for Code 14

Ethnicity

Ethnicity of Applicant or Borrower Collected on the

Basis of Visual Observation or Surname

Ethnicity

Ethnicity of Co-Applicant or Co-Borrower Collected on

the Basis of Visual Observation or Surname

Ethnicity

Race of Applicant or Borrower: 1

Race

Race of Applicant or Borrower: 2

Race

Race of Applicant or Borrower: 3

Race

Race of Applicant or Borrower: 4

Race

Race of Applicant or Borrower: 5

Race

Race of Applicant or Borrower: Conditional Free Form

Text Field for Code 1

Race

Race of Applicant or Borrower: Conditional Free Form

Text Field for Code 27

Race

Race of Applicant or Borrower: Conditional Free Form

Text Field for Code 44

Race

Race of Co-Applicant or Co-Borrower: 1

Race

Race of Co-Applicant or Co-Borrower: 2

Race

Race of Co-Applicant or Co-Borrower: 3

Race

Race of Co-Applicant or Co-Borrower: 4

Race

Race of Co-Applicant or Co-Borrower: 5

Race

Race of Co-Applica

ee Form

Text Field for Code 27

Race

Race of Applicant or Borrower: Conditional Free Form

Text Field for Code 44

Race

Race of Co-Applicant or Co-Borrower: 1

Race

Race of Co-Applicant or Co-Borrower: 2

Race

Race of Co-Applicant or Co-Borrower: 3

Race

Race of Co-Applicant or Co-Borrower: 4

Race

Race of Co-Applicant or Co-Borrower: 5

Race

Race of Co-Applicant or Co-Borrower: Conditional Free

Form Text Field for Code 1

Race

Race of Co-Applicant or Co-Borrower: Conditional Free

Form Text Field for Code 27

Race

Race of Co-Applicant or Co-Borrower: Conditional Free

Form Text Field for Code 44

Race

Race of Applicant or Borrower Collected on the Basis of

Visual Observation or Surname

Race

Race of Co-Applicant or Co-Borrower Collected on the

Basis of Visual Observation or Surname

Race

Sex of Applicant or Borrower

Sex

Sex of Co-Applicant or Co-Borrower

Sex

Sex of Applicant or Borrower Collected on the Basis of

Visual Observation or Surname

Sex

Sex of Co-Applicant or Co-Borrower Collected on the

Basis of Visual Observation or Surname

Sex

Age of Applicant or Borrower

Age

# Data Field Name

Data Point Name

Age of Co-Applicant or Co-Borrower

Age

Income

Type of Purchaser

Rate Spread

HOEPA Status

Lien Status

Credit Score of Applicant or Borrower

Credit Score

Credit Score of Co-Applicant or Co-Borrower

Credit Score

Applicant or Borrower, Name and Version of Credit

Scoring Model

Credit Score

Applicant or Borrower, Name and Version of Credit

Scoring Model: Conditional Free Form Text Field For

Code 8

Credit Score

Co-Applicant or Co-Borrower, Name and Version of

Credit Scoring Model

Credit Score

Co-Applicant or Co-Borrower, Name and Version of

Credit Scoring Model: Conditional Free Form Text Field

For Code 8

Credit Score

Reason for Denial: 1

Reason for Denial

Reason f

or Borrower, Name and Version of Credit

Scoring Model: Conditional Free Form Text Field For

Code 8

Credit Score

Co-Applicant or Co-Borrower, Name and Version of

Credit Scoring Model

Credit Score

Co-Applicant or Co-Borrower, Name and Version of

Credit Scoring Model: Conditional Free Form Text Field

For Code 8

Credit Score

Reason for Denial: 1

Reason for Denial

Reason for Denial: 2

Reason for Denial

Reason for Denial: 3

Reason for Denial

Reason for Denial: 4

Reason for Denial

Reason for Denial: Conditional Free Form Text Field for

Code 9

Reason for Denial

Total Loan Costs

Total Loan Costs or Total

Points and Fees

Total Points and Fees

Total Loan Costs or Total

Points and Fees

Origination Charges

Discount Points

Lender Credits

Interest Rate

Prepayment Penalty Term

Debt-to-Income Ratio

Combined Loan-To-Value Ratio

Combined Loan-To-Value

Ratio

Loan Term

Introductory Rate Period

Balloon Payment

Non-Amortizing Features

Interest-Only Payments

Non-Amortizing Features

Negative Amortization

Non-Amortizing Features

# Data Field Name

Data Point Name

Other Non-Amortizing Features

Non-Amortizing Features

Property Value

Manufactured Home Secured Property Type

Manufactured Home

Secured Property Type

Manufactured Home Land Property Interest

Manufactured Home Land

Property Interest

Total Units

Multifamily Affordable Units

Submission of Application

Application Channel

Initially Payable to Your Institution

Application Channel

Mortgage Loan Originator NMLSR Identifier

Mortgage Loan Originator

NMLSR Identifier

Automated Underwriting System: 1

Automated Underwriting

System

Automated Underwriting System: 2

Automate

tal Units

Multifamily Affordable Units

Submission of Application

Application Channel

Initially Payable to Your Institution

Application Channel

Mortgage Loan Originator NMLSR Identifier

Mortgage Loan Originator

NMLSR Identifier

Automated Underwriting System: 1

Automated Underwriting

System

Automated Underwriting System: 2

Automated Underwriting

System

Automated Underwriting System: 3

Automated Underwriting

System

Automated Underwriting System: 4

Automated Underwriting

System

100

Automated Underwriting System: 5

Automated Underwriting

System

101

Automated Underwriting System: Conditional Free

Form Text Field for Code 5

Automated Underwriting

System

102

Automated Underwriting System Result: 1

Automated Underwriting

System

103

Automated Underwriting System Result: 2

Automated Underwriting

System

104

Automated Underwriting System Result: 3

Automated Underwriting

System

105

Automated Underwriting System Result: 4

Automated Underwriting

System

106

Automated Underwriting System Result: 5

Automated Underwriting

System

107

Automated Underwriting System Result: Conditional

Free Form Text Field for Code 16

Automated Underwriting

System

108

Reverse Mortgage

109

Open-End Line of Credit

110

Business or Commercial Purpose

Business or Commercial

Purpose

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