HMDA Data Available
The FFIEC announced that the 2010 HMDA data is available. This included disclosure statements, which credit unions need to make available to the public. Credit unions should take note of their HMDA data, as the press release notes that these reports can be a starting point for fair lending examinations:
The HMDA data can facilitate the fair lending examination and enforcement process and promote market transparency. When federal banking agency examiners evaluate an institution's fair lending risk, they analyze HMDA data in conjunction with other information and risk factors, in accordance with the Interagency Fair Lending Examination Procedures (http://www.ffiec.gov/PDF/fairlend.pdf). Risk factors for pricing discrimination include, but are not limited to, the relationship between loan pricing and compensation of loan officers or mortgage brokers, the presence of broad pricing discretion, and consumer complaints.
The HMDA data alone cannot be used to determine whether a lender is complying with fair lending laws. They do not include many potential determinants of creditworthiness and loan pricing, such as the borrower's credit history, debt-to-income ratio, and the loan-to-value ratio. Therefore, when the federal banking agencies conduct fair lending examinations, including ones involving loan pricing, they analyze additional information before reaching a determination regarding institutionsâ compliance with fair lending laws.