HMDA: What is Your HMDA Data Telling You?
By David Dickinson
Here are some more notes from the ABA's Regulatory Compliance Conference. I attended a session on analyzing your institution's HMDA data that was very good. Below are my notes from this session.
1. Analyze your data now (before submitting). Not after you report it.
- Periodically (quarterly, semi-annually, annually?) review your data and know what it is telling you AND why.
- Be ready to defend your data.
- Feel free to add other data to your HMDA LAR (FICO scores, debt to income, loan to value, etc.).
2. Can you explain ethnic, racial or gender disparities? Compare denials and pricing information on these categories.
3. Review the time between application and action dates. Why do some take so long?
4. Review rate spreads and HOEPA loans.
5. Look for conspicuous lending gaps.
6. Explain your data:
- Is there anything that looks odd to you?
- What does it mean to you?
- What will it mean to the public?
- Is it consistent with your institution's strategic goals?
- Are results different by lending departments/channels/products? Why?
- Are results different among your lenders and/or brokers?
7. If the HMDA data isn't correct, it trickles into several other areas (CRA Exam and CALL reports) which are not correct either.
"We expect banks to be self identifiers" - Calvin Hagins, Director of Compliance Policy, OCC