Home Mortgage Disclosure Act (HMDA) Disclosure Statements: A Comprehensive Overview

The Home Mortgage Disclosure Act (HMDA) mandates the collection and disclosure of mortgage loan data by various financial institutions, including credit unions, to promote fair lending practices and ensure equal access to credit. HMDA disclosure statements play a crucial role in this process by providing comprehensive information about a credit union’s mortgage lending activities. This article explores the requirements, availability, and significance of HMDA disclosure statements, drawing upon authoritative sources such as the Consumer Financial Protection Bureau (CFPB) and the National Credit Union Administration (NCUA).

Key Facts

  1. HMDA Disclosure Statement: This statement provides a summary of a credit union’s HMDA data. It must be made available to the general public upon request, either in paper or electronic form, and should remain available for a period of five years.
  2. Modified Loan/Application Register (LAR) Availability Notice: The modified LAR, which contains detailed loan-level data, is also available to the general public upon request. Credit unions that submit HMDA data are required to provide a notice to the general public about the availability of the modified LAR.

It’s important to note that the specific requirements and guidelines for HMDA disclosure statements may vary, so it’s advisable to consult the official regulations and guidance provided by the Consumer Financial Protection Bureau (CFPB) and other relevant authorities.

HMDA Disclosure Statement: A Summary of Key Information

The HMDA disclosure statement presents a summary of a credit union’s HMDA data, offering insights into its mortgage lending practices. This statement must be made available to the general public upon request, either in paper or electronic form. Credit unions are required to retain the disclosure statement for a period of five years, ensuring its accessibility to interested parties.

Modified Loan/Application Register (LAR) Availability Notice: Access to Detailed Loan-Level Data

In addition to the HMDA disclosure statement, the modified LAR, which contains detailed loan-level data, is also available to the general public upon request. Credit unions that submit HMDA data are required to provide a notice to the general public about the availability of the modified LAR. This notice should clearly convey that the modified LAR can be obtained on the CFPB’s website.

Significance of HMDA Disclosure Statements: Promoting Transparency and Accountability

HMDA disclosure statements serve as valuable tools for promoting transparency and accountability in mortgage lending. They enable various stakeholders, including consumers, community organizations, and policymakers, to assess a credit union’s lending patterns and identify any potential disparities in access to credit. This information can inform policy decisions, facilitate fair lending practices, and empower consumers to make informed choices about mortgage products and services.

Conclusion

HMDA disclosure statements play a vital role in ensuring transparency and accountability in mortgage lending. By providing a summary of a credit union’s HMDA data and facilitating access to the modified LAR, these statements empower consumers, community organizations, and policymakers to assess lending patterns and promote fair lending practices. HMDA disclosure statements are essential tools for fostering a more equitable and inclusive mortgage lending environment.

Sources

  1. Consumer Financial Protection Bureau. (n.d.). Home Mortgage Disclosure Act (HMDA) Data. Retrieved from https://www.consumerfinance.gov/data-research/hmda/
  2. Consumer Financial Protection Bureau. (2023, March 1). Regulation C: Disclosure and reporting. Retrieved from https://www.consumerfinance.gov/rules-policy/regulations/1003/5/
  3. National Credit Union Administration. (n.d.). Additional Information about Home Mortgage Disclosure Act Data Collection Requirements for Calendar Year 2018 and Changes to Data Notices. Retrieved from https://www.ncua.gov/regulation-supervision/regulatory-compliance-resources/consumer-compliance-regulatory-resources/fair-lending-compliance-resources/additional-information-hmda-data-collection-2018

FAQs

1. What is an HMDA disclosure statement?

An HMDA disclosure statement is a summary of a credit union’s HMDA data, providing insights into its mortgage lending practices.

2. Who is required to provide an HMDA disclosure statement?

Credit unions that meet specific criteria, such as asset size, location, and lending volume, are required to submit HMDA data and provide a disclosure statement.

3. What information is included in an HMDA disclosure statement?

An HMDA disclosure statement typically includes information such as the number and types of mortgage loans originated, the geographic distribution of lending, and the characteristics of borrowers, such as race, ethnicity, and income.

4. How can the public access an HMDA disclosure statement?

The public can request an HMDA disclosure statement from the credit union’s home office or any branch office physically located in a Metropolitan Statistical Area or Metropolitan Division. Credit unions may also provide the statement electronically on their website.

5. How long must credit unions retain HMDA disclosure statements?

Credit unions are required to retain HMDA disclosure statements for a period of five years.

6. What is the modified Loan/Application Register (LAR) Availability Notice?

The modified LAR Availability Notice informs the public that the credit union’s loan/application register, as modified by the CFPB to protect applicant and borrower privacy, can be obtained on the CFPB’s website.

7. Where can the public find the modified LAR?

The public can access the modified LAR on the CFPB’s website.

8. Why are HMDA disclosure statements important?

HMDA disclosure statements promote transparency and accountability in mortgage lending, enabling stakeholders to assess lending patterns and identify potential disparities in access to credit.