On April 1, 2020, the Consumer Financial Protection Bureau (CFPB) released the Modified Loan Application Registers (LARs) reflecting 2019 mortgage lending activity reported under the Home Mortgage Disclosure Act (HMDA). These reports represent the second release of HMDA data under the new rule implemented in 2015. Starting in 2018, under the 2015 HMDA Rule, financial institutions were required to report new mortgage products (i.e., open-end lines of credit) and substantially more data elements (e.g., credit score, DTI, CLTV, interest rate, etc.) than in previous years.
While the Modified LARs are useful for analyzing mortgage activity for one institution, they offer limited benefits in benchmarking lender performance across markets and versus peers. If the CFPB’s data release schedule is consistent with its schedule for releasing 2018 data, we expect the first national 2019 dataset to benchmark performance will not be available until the end of August 2020.
While we await the availability of the complete loan level dataset, ADI has combined the Modified LARs of all 5,320 institutions as published on the CFPB’s website for 2019, into an aggregate loan-level dataset. This dataset, consisting of 17,071,751 applications and 2,483,379 loan purchases, is a preliminary snapshot of all HMDA-reported activity for 2019.
With these data we are able to benchmark our clients’ lending performance versus peers to support early analyses of 2019 activity related to Fair Lending, Redlining, the Community Reinvestment Act, and HMDA.
Please contact us if you have any needs for leveraging the insights of this preliminary snapshot of 2019 HMDA data.