The Federal Financial Institutions Examination Council (FFIEC) recently announced the release of the Snapshot National Loan-Level Dataset based on Home Mortgage Disclosure Act (HMDA) data from 2023. The CFPB also addressed the release of the dataset. Previously, we reported on the release by the CFPB of the HMDA Modified Loan Application Data for 2023, which did not include any analysis of the data.

The FFIEC advises that the Snapshot National Loan-Level Dataset contains the national HMDA datasets as of May 1, 2024, and that key observations from the Snapshot include the following:

  • The number of reporting institutions increased by about 14.6 % from 4,460 in 2022 to 5,113 in 2023. Previously, the number of reporting institutions increased about 2.63% from 4,338 in 2021 to 4,460 in 2022.
    • This likely reflects that for 2023 the CFPB reinstituted the HMDA reporting trigger of 25 originated covered loans in each of the prior two calendar years, based on a prior court decision that invalidated the change in the threshold from 25 to 100 covered loans in each of the prior two calendar years that was made in an April 2020 CFPB rule. The relatively modest increase would appear to call into question whether the 25 loan threshold is appropriate.
  • The 2023 data include information on 10 million home loan applications, that include 7.70 million closed-end credit applications and 2.1 million open-end credit applications. This is a significant decrease from the 14.3 million and 23.3 million home loan applications reported in the 2022 and 2021 data, respectively. The significant decrease in application volume likely reflects the higher interest rate environment in 2022 and 2023, particularly when compared to the very low interest rate environment of 2021.
    • The FFIEC notes that 266,000 applications were reported by financial institutions making use of Economic Growth, Regulatory Relief, and Consumer Protection Act’s partial exemptions from HMDA data reporting requirements, and that the institutions did not indicate whether the applications were for closed-end credit or open-end credit. We previously reported on the partial exemptions available to smaller mortgage loan volume depository institutions and credit unions that basically exempt such institutions from having to report the new HMDA data categories added by a HMDA rule adopted by the CFPB in October 2015.
  • The share of first lien, one- to four-family, site-built, owner-occupied, home-purchase loans originated by independent mortgage companies, which are not depository institutions, increased from 60.2% in 2022 to 68.8% in 2023. The 2023 percentage is also higher than the 63.9% independent mortgage company share for 2021.
  • The share of closed-end, first lien, one- to four-family, site-built, owner-occupied, home-purchase loans made to:
    • Black or African American borrowers rose from 8.1% in 2022 to 8.2% in 2023 (and the share was 7.9% for 2021).
    • Hispanic-White borrowers increased from 9.1% in 2022 to 9.9% 2023 (and the share was 9.2% in 2021).
    • Asian borrowers increased from 7.6% in 2022 to 7.7% in 2023 (and the share was 7.1% in 2021).
  • In 2022 the denial rates for closed-end, first lien, one- to four-family, site-built, owner-occupied, conventional, home purchase loans were:
    • 16.6% for Black or African American applicants, compared to 16.4% for 2022.
    • 12.0% for Hispanic-White applicants, compared to 11.1% for 2022.
    • 9.0% for Asian applicants, compared to 9.2% for 2022.
    • 5.8% for non-Hispanic-White applicants, which is the same as the denial rate for 2022.

The FFIEC announced the release of other data products, including the HMDA Dynamic National Loan-Level Dataset that is updated on a weekly basis to reflect late submissions and resubmissions, and Aggregate and Disclosure Reports that provide summary information on individual financial institutions and geographies. Additionally, the FFIEC advises that the HMDA Data Browser allows users to create custom tables and download datasets that can be further analyzed.