The Federal Financial Institutions Examination Council (FFIEC) released data on 2020 mortgage lending transactions at the 4,475 FIs that are required to report under the Home Mortgage Disclosure Act (HMDA) on June 17, 2021.
How to Build a Strong Fair Lending & Redlining Compliance Management System
This data includes 48 data points that provide information about the applicants, the property securing the loan (or proposed to secure the loan in the case of non-originated applications), the transaction, and identifiers. This data is a key component of our fair lending programs and provides insight into how consistent we are in our lending practices. It also allows for peer comparisons.
Additionally, the data allows us to understand how FIs are serving the housing needs of their local communities and facilitate federal financial regulators’ fair lending, consumer compliance, and Community Reinvestment Act (CRA) examinations. The FFIEC suggests that FIs include the HMDA Data Publication along with the Census demographic information in their fair lending analysis processes.
With those thoughts in mind, let’s focus on five takeaways from the 2020 data.
1. The number of reporting institutions declined by about 20 percent from 2019. A main reason for the change can be tied to the CFPB’s final rule amending Regulation C to increase the threshold for collecting and reporting data about closed-end mortgage loans from 25 to 100 loans. Sixty-one percent of loan applications were taken by non-depository, independent mortgage companies.
2. There were 22.7 million applications in 2020. Here is the breakdown:
- There were 20.4 million closed-end applications (an increase of 63.2 percent from 2019)
- There were 1.7 million open-end applications (a 19 percent decrease from 2019)
3. Originated closed-end loans increased by 67 percent over 2019. Of these, 3.4 million were refinances (a 150 percent increase).
4. Proportionally more mortgage loans to low- and moderate-income borrowers, but fewer refinances. From 2019 to 2020, the share of home purchase loans for first lien, 1-4 family, site-built, owner-occupied properties made to low- or moderate-income borrowers increased about two percent. The share of refinance loans for this segment declined about 4.5 percent.
5. Little change in lending to minority communities. In terms of borrower race and ethnicity:
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- There was a slight increase in lending to Black borrowers (7 percent to 7.3 percent) for first lien home purchase loans.
- Refinances to Black borrowers decreased by 1 percent.
- Denial rates:
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| Black borrowers: 17.2 percent |
| Hispanic-White borrowers: 11.2 percent |
| Asian: 9.1 percent |
| Non-Hispanic-White: 6.1 percent |
What do these data points tell us? While there was not a sharp year-over-year increase in applications for purchase loans in the low-to-moderate and minorities communities, refinances are a different story. The COVID-19 pandemic had a huge impact on this market segment—and we need to recognize that we are still feeling the impact of COVID on mortgage lending practices.
Going forward, FIs need to be diligent in reviewing and analyzing HMDA data in comparison to their own lending portfolio to see how they measure up against peers.
These five data snapshots provide good insight into how we did as a lending community. Utilizing this data can help your FI understand your story and identify any areas in need of attention.
Related: Is Your FI Complying with Fair Lending Laws? - Leverage Analytics
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