2018 HMDA Changes and Fair Lending Implications

While many institutions are diligently working to implement system changes in respect to Home Mortgage Disclosure Act (HMDA) 2018 enhancements, a far greater number of banks, mortgage companies and other financial institutions may not be prepared for the disclosure of information that could potentially identify disparate treatment or impact. With the introduction of significant underwriting fields into the HMDA Loan Application Register (LAR), examiners and regulators will have an enhanced ability to conduct fair lending examinations without setting foot within an institution.

Institutions should be prepared to proactively utilize these new fields (credit score, loan costs, type of loan, LTV, DTI, etc.) to conduct fair lending self-assessments. A complete list of HMDA's required fields can be located at: https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201710_cfpb_reportable-hmda-data_regulatory-and-reporting-overview-reference-chart.pdf. 

If you have any questions on developing or conducting fair lending self assessments, feel free to contact us for additional information.