Fair Lending Data at Risk!

The Home Mortgage Disclosure Act (HMDA) records nearly every mortgage application in the country by census tract. It also tracks data on the outcomes of these loans so we can see who is and isn’t getting mortgages based on race, ethnicity, gender, income, age, location, and more. The Dodd Frank Act added new data points to help analyze affordability, pricing, interest rates, and loan characteristics of 1-4 family and multifamily lending that can reveal further lending disparities and signs of predatory lending. The CFPB now wants to roll back much of that data and limit the number of lenders who report to HMDA at all.

HMDA Threat #1: The CFPB Wants to Allow More Banks to Hide Fair Lending Data

The CFPB wants to raise the threshold for who reports to HMDA to 50 or 100 loans, or even 250 or more. In other words, if a lender makes fewer than the threshold, none of their lending will be public. 

Read ANHD's Comment Letter to the CFPB.

HMDA Threat #2: The CFPB Wants to Rollback Critical Fair Lending Data

The CFPB has asked for comments regarding the value of new HMDA data required by the Dodd Frank Act of 2010. This new data included more demographic information about borrowers (race, ethnicity, disaggregated data, age, etc.), more information about loan terms and conditions, and more information about multifamily lending. The CFPB asks some skeptical and leading questions indicating they want to get rid of some or all of them entirely. Multifamily data is particularly at risk. The enhanced HMDA data is necessary to spot and deter abusive lending and to make sure that housing and credit needs are being met in a responsible fashion for traditionally underserved populations.

Read ANHD's Comment Letter to the CFPB.

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