Case Study | Home Mortgage Disclosure Act (HMDA

Case Study | Home Mortgage Disclosure Act (HMDA)

Summary + Historical Context
The Home Mortgage Disclosure Act (HMDA), originally enacted by Congress in 1975 and implemented by
Regulation C (Reg C), requires financial institutions such as residential mortgage lenders to maintain, collect,
record, report, and disclose data about their mortgage lending activity. Previously administered by the Federal
Reserve Board, following the Dodd-Frank Wall Street Reform and Consumer Protection Act, authority over HMDA
and Reg C has been transferred to the Consumer Financial Protection Bureau (CFPB).
Per Reg C, financial institutions must report HMDA data to the CFPB, in the form of a HMDA Loan Application
Register (LAR). Institutions which accept less than 60,000 loan applications per annum file the HMDA LAR
annually; institutions which exceed 60,000 loan applications in volume, must file the HMDA LAR quarterly.
Further, financial institutions must also notify the public when this data is published. Data reported to the CFPB
includes Government Monitoring Information (GMI)—race, ethnicity, and sex—collected upon submission of a
residential mortgage loan application via the Uniform Residential Loan Application (i.e. Form 1003).
Provision of this data allows the CFPB to assess whether lenders serve the housing needs of all communities.
Specifically, the HMDA LAR provides information which may inform amendments to CFPB policy, and may also
shed light on lending patterns which may be discriminatory in nature. The HMDA LAR is scrutinized at an
extensive and detailed level by the CFPB, which conducts examinations (audits) of residential mortgage lenders
every 36-48 months.
The Challenge
ABC Mortgage Bank (ABC) is an early-stage digital mortgage originator engaging in direct-to-consumer (D2C)
residential mortgage lending. You have been onboarded as the first hire of ABC’s Regulatory Strategy team,
reporting directly to ABC’s General Counsel (GC) and Chief Compliance Officer (CCO).
On your first day, you are informed that you will be responsible for our ABC’s HMDA filing. ABC has never
previously submitted a HMDA filing. Further, you yourself have scant experience with both HDMA and Reg C, and
may not have previous experience leveraging the data analytics and engineering-related skills required for the
accurate and timely submission of this filing.
Visualize a scenario in which you join ABC’s Regulatory Strategy team on February 1 and are independently and
solely responsible for submitting the HMDA LAR by March 1. Assume that ABC does not have HMDA policies or
procedures (P&Ps) in place. You are ABC’s first Regulatory Strategy hire; it is your job and privilege to develop
them! These P&Ps should include, but not be limited to: record procedures, action plan, database queries (SQL),
quality control (QC) procedures, et cetera.
You alone have full responsibility for this filing, and you will be informing Executive Leadership of your decisions,
but not necessarily always asking for sign-off. Further, you alone will be held accountable for any discrepancies
and/or the late filing of ABC’s HMDA LAR. In this scenario, you may choose to collaborate with the Product, Data,
and Engineering (PDE) teams. However, you are operating in an environment in which extra-Compliance
bandwidth is limited; PDE’s familiarity with the specifics of the HMDA LAR (e.g. the 110 data fields which must be
reported to the CFPB) is scant and/or non-existent. During these twenty-eight days, you will become the HMDA
subject matter expert for ABC.
How do you proceed?

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