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Washington, D.C. — UNC Center for Community Capital associate director Janneke Ratcliffe recommended in testimony today (Sept. 24) that the Federal Reserve Board preserve the unique features that make Home Mortgage Disclosure Act (HMDA) data so valuable while expanding and standardizing data collection to shore up important data gaps.

“In the 13 years that the center has studied how mortgage markets affect lower-income and minority households, HMDA has been vital,” Ratcliffe said. The center has used HMDA data to identify disparities in incidence of high-priced lending across borrowers, neighborhoods and regulatory environments. The ability to distinguish lender and neighborhood has been key to the center’s work in comparing Community Reinvestment Act lending with that of the overall market, she said.

“Still, HMDA left many critical questions unanswered and we see much promise in financial regulatory reform provisions for HMDA,” Ratcliffe said.

Ratcliffe offered seven key recommendations for the Federal Reserve to consider:

  • Preserve unique HMDA attributes that are critical to its core purposes; namely, that the data is public, disaggregated, covers applications as well as loans made, covers all loans (not just a sample) and is specific to geography and lender.
  • Expand data collection to add fields that are overdue, such as credit score and value — two factors most relied upon to assess risk and make loan decisions.
  • Standardize data definitions and reporting requirements across institutions and regulators to reduce the cost of compliance and improve the ease of data use.
  • Make HMDA data easier to use by developing an interactive user-interface for those without advanced data management capacity.
  • Ensure borrower privacy is preserved by providing aggregated tables for public access, using statistical conventions to present loan-level data in a form that protects individual borrower information, and make fuller data available under carefully controlled conditions.
  • Make loans traceable through a proposed universal loan identification variable to facilitate tracing of loan performance through the primary and secondary mortgage markets.
  • Institutionalize the reporting process, for example, with a timetable and advisory committee, to ensure the right information is available when needed to spot trends and potential problems with the housing finance system.

Ratcliffe testified at the last of four public hearings called by the Federal Reserve Board of Governors to receive input on possible changes to Regulation C, which implements HMDA. HMDA requires mortgage lenders to provide detailed reports about their mortgage lending activity to regulators and the public.

Ratcliffe’s recommendations reflected comments and input received in August from mortgage finance researchers, consumer advocates experienced in using HMDA data, and representatives of the private and public sector. At a forum co-hosted by the center with the Ford Foundation, participants suggested two new potentially valuable uses for an expanded HMDA dataset: using HMDA data to identify and anticipate products and services that may represent risk to the soundness of the financial system and to track outcomes (such as payment, foreclosure and loan modification) of various mortgage products.

View her testimony.

Mortgage finance is a major area of focus for the Center for Community Capital, the leading center for research and policy analysis on the transformative power of capital on households and communities in the United States. The center is part of the College of Arts and Sciences at the University of North Carolina at Chapel Hill. Its in-depth analyses help policymakers, advocates and the private sector find sustainable ways to expand economic opportunity to more people, more effectively. For more information, visit or call (919) 843-2140.

Topics(s): Affordable Homeownership, Mortgage Finance, Other, Testimony
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