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OCC BULLETIN 2017-41
To: Chief Executive Officers and Compliance Officers of National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties

Description: Interagency Key Fields

Summary

The Office of the Comptroller of the Currency (OCC) is issuing this bulletin to inform national banks, federal savings associations, and federal branches and agencies (collectively, banks) about “key fields” the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the OCC have determined examiners will typically use to test and validate the accuracy and reliability of home mortgage loan data collected beginning in 2018 pursuant to the Home Mortgage Disclosure Act (HMDA) rule issued October 15, 2015.

Note for Community Banks

This bulletin applies to all national banks, federal savings associations, and federal branches and agencies that are subject to HMDA data collection and reporting requirements.

Highlights

The FRB, the FDIC, and the OCC are issuing Designated Key HMDA Data Fields to support the efficient and effective evaluation of financial institutions’ compliance with the HMDA’s requirements. Of 110 data fields, 37 are identified as key fields. In certain circumstances, however, examiners may determine it necessary to review additional HMDA data fields, as appropriate.

Background

The HMDA, which is implemented by Regulation C (12 CFR 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 To ensure compliance with the 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 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. The guidelines themselves, however, do not establish designated key data fields. In an effort to promote efficiency, coordination, and consistency, the FRB, the FDIC, and the 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 the Designated Key HMDA Data Fields, the FRB, the FDIC, and the OCC considered a variety of factors, including the 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, the FDIC, and the OCC also took into account the likelihood that a data field would be reported correctly based on past examination experience.

Accordingly, to evaluate financial institutions’ compliance with HMDA requirements, FRB, FDIC, and OCC examination staffs will focus on the Designated Key HMDA Data Fields during transaction testing pursuant to the HMDA for data collected on or after January 1, 2018.5 In certain circumstances, however, consistent with the FFIEC guidelines, such examination staff may determine that it is necessary to review additional HMDA data fields, as appropriate.

As suggested above, proper reporting of HMDA data is important in assessing the accuracy of the HMDA data that financial institutions record and report. Where errors that exceed established thresholds6 are identified in an institution’s HMDA data, the OCC supervisory office has discretion to require the institution to correct specific errors, without requiring resubmission of the data. The supervisory office may require resubmission of HMDA data when the inaccurate data are indicative of systemic internal control weaknesses that call into question the integrity of the institution’s entire HMDA data report.

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
1 Record Identifier  
2 Legal Entity Identifier (LEI) Legal Entity Identifier (LEI)
3 Universal Loan Identifier (ULI) Universal Loan Identifier (ULI)
4 Application Date Application Date
5 Loan Type Loan Type
6 Loan Purpose Loan Purpose
7 Preapproval Preapproval
8 Construction Method Construction Method
9 Occupancy Type Occupancy Type
10 Loan Amount Loan Amount
11 Action Taken Action Taken
12 Action Taken Date Action Taken Date
13 Street Address Property Address
14 City Property Address
15 State Property Location & Property Address
16 Zip Code Property Address
17 County Property Location
18 Census Tract Property Location
19 Ethnicity of Applicant or Borrower: 1 Ethnicity
20 Ethnicity of Applicant or Borrower: 2 Ethnicity
21 Ethnicity of Applicant or Borrower: 3 Ethnicity
22 Ethnicity of Applicant or Borrower: 4 Ethnicity
23 Ethnicity of Applicant or Borrower: 5 Ethnicity
24 Ethnicity of Applicant or Borrower: Free Form Text Field for Other Hispanic or Latino Ethnicity
25 Ethnicity of Co-Applicant or Co-Borrower: 1 Ethnicity
26 Ethnicity of Co-Applicant or Co-Borrower: 2 Ethnicity
27 Ethnicity of Co-Applicant or Co-Borrower: 3 Ethnicity
28 Ethnicity of Co-Applicant or Co-Borrower: 4 Ethnicity
29 Ethnicity of Co-Applicant or Co-Borrower: 5 Ethnicity
30 Ethnicity of Co-Applicant or Co-Borrower: Free Form Text Field for Other Hispanic or Latino Ethnicity
31 Ethnicity of Applicant or Borrower Collected on the Basis of Visual Observation or Surname Ethnicity
32 Ethnicity of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname Ethnicity
33 Race of Applicant or Borrower: 1 Race
34 Race of Applicant or Borrower: 2 Race
35 Race of Applicant or Borrower: 3 Race
36 Race of Applicant or Borrower: 4 Race
37 Race of Applicant or Borrower: 5 Race
38 Race of Applicant or Borrower: Free Form Text Field for American Indian or Alaska Native Enrolled or Principal Tribe Race
39 Race of Applicant or Borrower: Free Form Text Field for Other Asian Race
40 Race of Applicant or Borrower: Free Form Text Field for Other Pacific Islander Race
41 Race of Co-Applicant or Co-Borrower: 1 Race
42 Race of Co-Applicant or Co-Borrower: 2 Race
43 Race of Co-Applicant or Co-Borrower: 3 Race
44 Race of Co-Applicant or Co-Borrower: 4 Race
45 Race of Co-Applicant or Co-Borrower: 5 Race
46 Race of Co-Applicant or Co-Borrower: Free Form Text Field for American Indian or Alaska Native Enrolled or Principal Tribe Race
47 Race of Co-Applicant or Co-Borrower: Free Form Text Field for Other Asian Race
48 Race of Co-Applicant or Co-Borrower: Free Form Text Field for Other Pacific Islander Race
49 Race of Applicant or Borrower Collected on the Basis of Visual Observation or Surname Race
50 Race of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname Race
51 Sex of Applicant or Borrower Sex
52 Sex of Co-Applicant or Co-Borrower Sex
53 Sex of Applicant or Borrower Collected on the Basis of Visual Observation or Surname Sex
54 Sex of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname Sex
55 Age of Applicant or Borrower Age
56 Age of Co-Applicant or Co-Borrower Age
57 Income Income
58 Type of Purchaser Type of Purchaser
59 Rate Spread Rate Spread
60 HOEPA Status HOEPA Status
61 Lien Status Lien Status
62 Credit Score of Applicant or Borrower Credit Score
63 Credit Score of Co-Applicant or Co-Borrower Credit Score
64 Applicant or Borrower, Name and Version of Credit Scoring Model Credit Score
65 Applicant or Borrower, Name and Version of Credit Scoring Model: Conditional Free Form Text Field For Code 8 Credit Score
66 Co-Applicant or Co-Borrower, Name and Version of Credit Scoring Model Credit Score
67 Co-Applicant or Co-Borrower, Name and Version of Credit Scoring Model: Conditional Free Form Text Field for Code 8 Credit Score
68 Reason for Denial: 1 Reason for Denial
69 Reason for Denial: 2 Reason for Denial
70 Reason for Denial: 3 Reason for Denial
71 Reason for Denial: 4 Reason for Denial
72 Reason for Denial: Conditional Free Form Text Field for Code 9 Reason for Denial
73 Total Loan Costs Total Loan Costs or Total Points and Fees
74 Total Points and Fees Total Loan Costs or Total Points and Fees
75 Origination Charges Origination Charges
76 Discount Points Discount Points
77 Lender Credits Lender Credits
78 Interest Rate Interest Rate
79 Prepayment Penalty Term Prepayment Penalty Term
80 Debt-to-Income Ratio Debt-to-Income Ratio
81 Combined Loan-To-Value Ratio Combined Loan-To-Value Ratio
82 Loan Term Loan Term
83 Introductory Rate Period Introductory Rate Period
84 Balloon Payment Non-Amortizing Features
85 Interest-Only Payments Non-Amortizing Features
86 Negative Amortization Non-Amortizing Features
87 Other Non-Amortizing Features Non-Amortizing Features
88 Property Value Property Value
89 Manufactured Home Secured Property Type Manufactured Home Secured Property Type
90 Manufactured Home Land Property Interest Manufactured Home Land Property Interest
91 Total Units Total Units
92 Multifamily Affordable Units Multifamily Affordable Units
93 Submission of Application Application Channel
94 Initially Payable to Your Institution Application Channel
95 Mortgage Loan Originator NMLSR Identifier Mortgage Loan Originator NMLSR Identifier
96 Automated Underwriting System: 1 Automated Underwriting System
97 Automated Underwriting System: 2 Automated Underwriting System
98 Automated Underwriting System: 3 Automated Underwriting System
99 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 Reverse Mortgage
109 Open-End Line of Credit Open-End Line of Credit
110 Business or Commercial Purpose Business or Commercial Purpose

Further Information

Please contact the OCC’s Compliance Risk Policy Division at (202) 649-5470.

 

Grovetta N. Gardineer
Senior Deputy Comptroller for Compliance and Community Affairs

 

1 12 USC 2801 et seq.

2 80 Fed. Reg. 66127 (October 28, 2015), as further amended.

3 Beginning with data collected on or after January 1, 2018, financial institutions subject to the HMDA will collect and report data on covered loans specified in 12 CFR 1003.4(a)(1)-(38) on a loan application register containing 110 data fields, as specified in the Federal Financial Institutions Examination Council Filing Instructions Guide (FIG). The FIG is available on the FFIEC website or the Consumer Financial Protection Bureau (CFPB) website.

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. The HMDA is among these laws and regulations.

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

6 The information provided in this bulletin supplements guidance issued on August 25, 2017, through OCC Bulletin 2017-31, “FFIEC HMDA Examiner Transaction Testing Guidelines,” which indicates examiners should direct a bank to correct any data field in its full HMDA Loan/Application Register (LAR) for any field where the error rate exceeds the stated resubmission threshold. The bank may also be required in such cases to resubmit its HMDA LAR with the corrected data field(s). However, OCC examiners will consult with their supervisory office, and as applicable Compliance Supervision Management, to determine whether resubmission is required based on specific facts and circumstances.