The press release from the FFIEC provided a number of observations regarding the 2013 data, including the following:
• Total originations declined about 11% from 2012;
• Refinances declined by 23%, while purchases increased by about 13%;
• FHA-insured purchase loans dropped 7% from 2012;
• HPML’s accounted for less than 5% of first-lien loan originations, which is an increase from around 3% in 2012. This is likely at least in part due to an increase in FHA-insured purchase loans exceeding the HPML threshold (as a result of an increase in the FHA Mortgage Insurance Premium); and,
• Similar to prior years, Black and Hispanic white applicants had higher rates of denial for conventional purchase loans than non-Hispanic white applicants. The denial rate for Asian applicants was more comparable to the rate for non-Hispanic white applicants.
The disclosure statement from the FFIEC should be available at your main office and be included within your CRA public file within three business days of receipt. It shall be retained for 5 years. If you have branch offices in other Metropolitan Statistical Areas, the disclosure statement must either be made available in at least one branch office in each MSA or the bank may post the address for sending written requests in the lobby of each branch in an MSA. Branch statements only need to include information for the specific MSA where the branch is located.
Also included in this announcement, was a draft article slated to appear in a future Federal Reserve Bulletin; which provides a more in-depth trend analysis of the data. The article looks at a number of factors that likely played a role in the data and may be helpful in explaining your own trends.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!