FRHMDALAR_20181128_omb

Supporting Statement for the
Reporting, Recordkeeping, and Disclosure Requirements Associated with the
Home Mortgage Disclosure Act Loan/Application Register required by Regulation C
(FR HMDA LAR; OMB No. 7100-0247)
Summary
The Board of Governors of the Federal Reserve System (Board), under delegated
authority by the Office of Management and Budget (OMB), proposes to extend for three years,
with revision, the Reporting, Recordkeeping, and Disclosure Requirements Associated with the
Home Mortgage Disclosure Act (HMDA) Loan/Application Register Required by Regulation C.1
Although the Bureau of Consumer Financial Protection (Bureau) is now responsible for issuing
HMDA regulations, the Paperwork Reduction Act (PRA) requires the Board to renew every
three years the information collections required of institutions the Board supervises.
HMDA was enacted in 1975 and is implemented by Regulation C. Generally, HMDA
requires certain depository and non-depository institutions that make certain mortgage loans to
collect, report, and disclose data about originations and purchases of mortgage loans, as well as
loan applications that do not result in originations (for example, applications that are denied or
withdrawn). HMDA was enacted to provide regulators and the public with loan data that can be
used to (1) help determine whether financial institutions are serving the housing needs of their
communities, (2) assist public officials in distributing public-sector investments so as to attract
private investment to areas where it is needed, and (3) assist in identifying possible
discriminatory lending patterns and enforcing anti-discrimination statutes.2 Supervisory
agencies, state and local public officials, and members of the public use the data to aid in the
enforcement of the Community Reinvestment Act, the Equal Credit Opportunity Act, and the
Fair Housing Act and to aid in identifying areas for residential redevelopment and rehabilitation.
Consistent with the Bureau’s final rules amending Regulation C, effective
January 1, 2018, as well as recent statutory amendments to HMDA that were enacted on
May 24, 20183, the Board proposes to revise the FR HMDA LAR by expanding the data reported
and by modifying the types of institutions required to report and the types of loans required to be
reported. The Board accounts for the paperwork burden associated with the regulation only for
Board-supervised institutions.4 For those institutions, the current annual paperwork burden for
the FR HMDA LAR is estimated to be 511,035 hours. With the proposed revisions, the
paperwork burden will increase to 673,474 hours, of which 88,880 hours are associated with
one-time burden.
1

HMDA is codified at 12 U.S.C. 2801-2810; Regulation C is located at 12 CFR Part 1003.
See 12 CFR 1003.1(b).
3
On May 24, 2018, the President signed into law the Economic Growth, Regulatory Relief, and Consumer
Protection Act (EGRRCPA). Section 104(a) of EGRRCPA amends HMDA to exempt certain insured depository
institutions and insured credit unions from collecting and reporting those data fields that were required by HMDA
sections 304(b)(5) and (6), as implemented by the Bureau’s final rules.
4
Other federal agencies account for the paperwork burden that Regulation C imposes on the institutions for which
they have administrative enforcement authority. These other federal agencies are the Department of Housing and
Urban Development (HUD), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union
Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Bureau.
2

Background and Justification
On July 21, 2011, rulemaking authority for HMDA was transferred from the Board to the
Bureau under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (DoddFrank Act). The Dodd-Frank Act also transferred HMDA supervisory and enforcement authority
for large depository institutions over $10 billion from the Board, FDIC, OCC, and NCUA to the
Bureau.
On October 15, 2015, the Bureau issued final rules5 that expand the data collected and
reported under the HMDA, which is implemented by Regulation C (final rules).6 The final rules
also modify the types of lenders and loans covered under Regulation C. Information collections
under the changes made by the final rules began in January 2018.
On May 24, 2018, the President signed into law EGRRCPA. Section 104(a) of
EGRRCPA amends HMDA to exempt certain insured depository institutions and insured credit
unions from collecting and reporting those data fields that were required by HMDA sections
304(b)(5) and (6), as implemented by the Bureau’s final rules in Regulation C. Section 104(a) of
EGRRCPA further provides that an institution is not eligible for this partial exemption, and
therefore must collect and report these data points, if it received ratings of “needs to improve” in
its two most recent Community Reinvestment Act (CRA) examinations or “substantial
noncompliance” in its most recent CRA examination. On July 5, 2018, the Bureau issued a
statement that generally outlined the availability of the partial exemption for eligible institutions,
and stated that additional guidance on the applicability of section 104(a) of EGRRCPA to
HMDA data collected in 2018 would be forthcoming.7
Description of Information Collection
HMDA, implemented by Regulation C, requires covered institutions to collect, record,
report, and disclose information about their mortgage lending activity.
Information Collection Prior to January 1, 2018
Prior to January 1, 2018, Regulation C required an institution to report loan data under
HMDA if it has at least one home or branch office in a metropolitan statistical area (MSA) and
also meets certain coverage tests. The coverage tests differed based on whether the lender was a
depository or a non-depository lender:

5

See 80 FR 66127 (Oct. 28, 2015).
These data fields are discussed in the “Description of Information Collection” below.
7
This statement is discussed further in the “Description of Information Collection” below. See Bureau of
Consumer Financial Protection Issues Statement on the Implementation of the Economic Growth, Regulatory Relief,
and Consumer Protection Act Amendments to the Home Mortgage Disclosure Act at
https://www.consumerfinance.gov/about-us/newsroom/bureau-consumer-financial-protection-issues-statementimplementation-economic-growth-regulatory-relief-and-consumer-protection-act-amendments-home-mortgagedisclosure-act/ (July 5, 2018) (Bureau Statement).
6

2




Depository institutions were covered by HMDA if they had assets exceeding $44 million8
as of December 31, 2016 and originated at least one first-lien home purchase or home
refinance loan in the preceding year (regardless of other home secured loans).9
Non-depository mortgage lenders were covered by HMDA if they had assets exceeding
$10 million or originated at least 100 home purchase or home refinance loans in the
preceding year.10

Prior to January 1, 2018, Regulation C required lenders to report only closed-end,
dwelling-secured applications and loans that are made for the purpose of home purchase, home
improvement or refinancing. It also required lenders to report home improvement loans that are
not secured by the dwelling, and reporting of home equity lines of credit (HELOCs) was
optional.
Prior to January 1, 2018, Regulation C required a covered institution to collect and report
data points about




each application or loan, including the application date; the action taken and the date of
that action; the loan amount; the loan type (for example, government guaranteed or not)
and purpose (for example, home purchase); and, if the loan is sold, the type of purchaser
each applicant or borrower, including ethnicity, race, sex, and income
each property, including location and occupancy status

Reporting institutions historically have been submitting HMDA/LAR data to the Board,
which has been collecting the data on behalf of the applicable Federal supervisory agency. Then,
the data was combined and aggregated for each Metropolitan Statistical Area (MSA).
Aggregated data reflecting information reported under the Regulation C requirements prior to
January 1, 2018, (that is, not the requirements of the final rules) is publicly available.11
Proposed Revisions to the Information Collection
Consistent with the Bureau’s final rules amending Regulation C, effective January 1,
2018, as well as recent statutory amendments to HMDA that were enacted on May 24, 2018,12
the Board proposes to revise the FR HMDA LAR by expanding the data reported and by
8

The asset-size threshold amount is adjusted annually based on the annual percentage change of the Consumer
Price Index for Urban Wage Earners and Clerical Workers.
9
In addition, the depository institution must be federally insured or regulated, or the loan must be related to a
federal loan program or intended for sale to one of the Government-sponsored enterprises (GSEs).
10
The non-depository lender’s home purchase and home refinance loans must also equal at least 10 percent of its
loan origination volume or equal at least $25 million.
11
The disclosure statements and aggregate data for 2016 data will be produced by Board staff on behalf of the
FFIEC until December 31, 2017. Beginning January 1, 2018, HMDA data will begin to be reported to and disclosed
by the Bureau. For example, institutions will report 2017 data to the Bureau by March 1, 2018. In addition,
beginning in 2018, institutions will be required to use a new web-based system to report their HMDA data.
12
As described above, section 104(a) of EGRRCPA amends HMDA to exempt certain insured depository
institutions and insured credit unions from collecting and reporting those data fields that were required by HMDA
sections 304(b)(5) and (6), as implemented by the Bureau’s final rules.

3

modifying the types of institutions required to report and the types of loans required to be
reported. Beginning January 1, 2018, an institution that is otherwise not eligible for a partial
exemption under section 104(a) of EGRRCPA, as discussed further below, is required to collect
and report all required data points required under HMDA if it either originates 25 or more13
closed-end mortgage loans or 500 or more open-end lines of credit14 secured by a dwelling in
each of the two preceding years, in addition to meeting other applicable coverage criteria. 15 For
these institutions, the final rules standardize the loan volume threshold used to determine
coverage of both depository and non-depository institutions. An institution will only report a
covered loan if it has met the loan origination threshold for that loan category (open-end or
closed-end).
The final rules generally will require covered institutions to collect and report any
mortgage loan secured by a dwelling, including open-end lines of credit, regardless of the loan’s
purpose. However, the final rules exclude unsecured home-improvement loans (which
historically were required to be reported), dwelling-secured loans that are made principally for a
commercial or business purpose, agricultural–purpose loans, and other specifically excluded
loans.16
The final rules also will require collection of additional data points. For covered
institutions that are otherwise not eligible for the partial exemption under section 104(a) of
EGRRCPA, as discussed further below, these additional data points will be reported in 2019.
These new fields include





additional information about the applicant or borrower, such as age and credit score
information about the loan pricing, such as the borrower’s total cost to obtain a mortgage,
temporary introductory rates, and borrower-paid origination charges
information about loan features, such as the loan term, prepayment penalties, or nonamortizing features (such as interest only or balloon payments)
additional information about property securing the loan, such as property value and
property type

In addition, the Bureau’s final rules amend several existing requirements, including the
requirements for collection and reporting of information regarding an applicant’s or borrower’s
ethnicity, race and sex.17

13

Small depository institutions that originated fewer than 25 closed-end mortgage loans in either 2015 or 2016
ceased HMDA data collection on January 1, 2017.
14
Under the 2015 final rules, financial institutions would have been required to report home-equity lines of credit if
they made 100 or more such loans in each of the last two years. On August 24, 2017, the Bureau amended the final
rules to increase the institutional coverage and loan threshold from 100 to 500 or more loans through calendar years
2018 and 2019. See 82 FR 43088 (Sept. 13, 2017). This temporary increase in the threshold will provide time for
the Bureau to consider whether to initiate another rulemaking to address the appropriate level for the threshold for
data collected beginning January 1, 2020.
15
Asset size and geographic location coverage tests also apply. See 12 CFR 1003.2(g).
16
See 12 CFR 1003.2(e).
17
For the complete list of data points, see 12 CFR 1003.4.

4

Effective May 24, 2018, an institution that is eligible for the partial exemption under
section 104(a) of EGRRCPA will only need to report a subset of the data points required under
HMDA if it originates fewer than 500 closed-end mortgage loans in each of the two preceding
calendar years.18 Consistent with section 104(a) of EGRRCPA and the Bureau’s recent
statement addressing the applicability of this statutory amendment to HMDA,19 the Board
estimates that institutions eligible for the partial exemption will report approximately half the
data points currently required by the Bureau’s final rules on the loans described above.20
The Bureau will collect the HMDA LAR data on behalf of the applicable Federal
supervisory agency, and the data will be combined and aggregated for each Metropolitan
Statistical Area (MSA). Certain aggregated data will continue to be publicly available, though
the Bureau has yet to determine what the information collected in the new data fields will be
disclosed once the final rules are fully effective.
Respondent Panel
The FR HMDA LAR panel comprises the following types of institutions, except those
that are supervised by the Bureau: state member banks, their subsidiaries, subsidiaries of bank
holding companies, U.S. branches and agencies of foreign banks (other than federal branches,
federal agencies, and insured state branches of foreign banks), commercial lending companies
owned or controlled by foreign banks, and organizations operating under section 25 or 25A of
the Federal Reserve Act (12 U.S.C. 601-604a; 611-631). The Bureau supervises, among other
institutions, insured depository institutions with over $10 billion in assets and their affiliates
(including affiliates that are themselves depository institutions regardless of asset size and
subsidiaries of such affiliates).

18

Section 104(a) of EGRRCPA also provides a partial exemption to the data collection and reporting requirements
under HMDA for institutions that originate fewer than 500 open-end lines of credit in each of the two preceding
calendar years and otherwise meet the applicable performance evaluation rating standards under CRA. However,
institutions eligible for this partial exemption are already completely exempt from all data collection and reporting
requirements under the temporary exemption provided by the Bureau’s final rules until January 1, 2020.
19
See Bureau Statement, which provides that for loans subject to the partial exemption, “the requirements of
[HMDA section 304(b)(5) an (6)] shall not apply . . .[therefore,] institutions are exempt from the collection,
recording, and reporting requirements for some, but not all, of the data points specified in current Regulation C.”
20
Section 104(a) of EGRRCPA does not define the terms “closed-end loan” or “open-end line of credit.” However,
for purposes of estimating burden, the Board is making the assumption that these terms will be used consistent with
how they are currently defined in Regulation C. See 12 CFR 1002.2(d) and (o), which defines the term “closed-end
loan” and “open-end line of credit,” respectively. Further, for purposes of estimating burden, the Board is making
the assumption that the loan volume thresholds for closed-end loans will be determined consistent with how such
loan thresholds are currently used under Regulation C to determine if a transaction must be reported. See 12 CFR
1003.3(c)(11) and (12), which provides how to determine the loan threshold volume for closed-end loan reporters
and open-end line of credit reporters, respectively.

5

Time Schedule for Information Collection
Recordkeeping Requirements
Information Collection Prior to January 1, 2018
Under Regulation C, a covered institution must record data from mortgage lending
applications and loans, which it then reports to the applicable Federal supervisory agency,
discussed below in “Reporting Requirements.” Prior to January 1, 2018, an institution was
required to record data on each application and loan within 30 days after the end of the calendar
quarter during which the institution took final action.
A covered institution was also subject to recordkeeping requirements after data is
reported. For three years, a covered institution was required to retain its LAR, the document
which contains the recorded data on each application and loan.
Proposed Revisions to the Information Collection
These requirements will continue to apply after the Bureau’s final rules are effective,
though covered institutions will be required to collect and record additional data points, as
discussed above in the “Description of Information Collection.”21
Reporting Requirements
Information Collection Prior to January 1, 2018
Prior to January 1, 2018, a covered institution was required to submit to the applicable
Federal supervisory agency a completed LAR. Each covered institution was required to submit
annually the completed LAR to the applicable Federal supervisory agency by March 1st of the
year following the year covered by the LAR.
Proposed Revisions to the Information Collection
The annual reporting requirement, described above, will continue once the final rules
become effective. However, in 2019, covered institutions must submit the completed LAR
electronically to the Bureau, which will collect the data on behalf of the applicable Federal
supervisory agency, using a new web-based submission tool.22 In addition, effective first quarter
2020, the final rules require institutions with a high volume of lending to also electronically
submit their HMDA data for the first three quarters of the year on a quarterly basis, within 60
days of the end of each quarter.23 Those institutions subject to quarterly reporting requirements
21

The requirement to record data within 30 days is in 12 CFR 1003.4(f) (previously 12 CFR 1003.4(a)). The
requirement to retain the LAR for three years is in 12 CFR 1003.5(d).
22
For institutions eligible for the partial exemption under section 104(a) of EGRRCPA and filing HMDA data
collected in 2018, EGRRCPA will not affect the format of the LARs. If an institution does not need to report a
specified data point under the partial exemption, then the institution will enter an exemption code for the field,
which will be specified by the Bureau in forthcoming guidance. See Bureau Statement.
23
See 12 CFR 1003.5(a). The first quarterly submission will be due May 30, 2020.

6

(quarterly reporters) will be those that reported 60,000 or more applications and covered loans
(combined) in the preceding calendar year, excluding purchased loans. Quarterly reporters are
not required to certify their quarterly reports for accuracy, but continue to be required to submit
certified HMDA data on an annual basis (i.e., March 1st annual report). In addition, all reporting
institutions that submit incorrect information may be required to correct and resubmit the
information.
Disclosure Requirements
Information Collection Prior to January 1, 2018
Prior to January 1, 2018, the Federal Financial Institutions Examination Council (FFIEC)
prepared an individual disclosure statement for each financial institution using the HMDA data
that each financial institution submitted on its LAR, and provided the statement to the covered
institution. Within three business days of receiving its public disclosure statement from the
FFIEC, the institution was required to make a copy available to the public at its home office. In
addition, within 10 business days of receiving its public disclosure statement, the institution was
required to either make the public disclosure statement available in at least one branch office in
every MSA and Metropolitan Division (Division) where it had an office or post a notice in at
least one branch office per MSA and Division where it had an office stating that the statement is
available upon written request. If requested, the covered institution need only provide the
portion of data relating to the MSA or Division for which the request is made. A covered
institution was required to make each public disclosure statement available to the public for five
years. In addition, for three years, a covered institution was required to provide to the public,
upon request, its modified LAR, which was the institution’s LAR that has certain information
redacted to protect the privacy of its applicants and borrowers.
Proposed Revisions to the Information Collection
In 2018, covered institutions will no longer be required to provide either the public
disclosure statement or modified LAR upon request. Instead, under the final rules, covered
institutions must provide a notice for five years that states its public disclosure statement and
modified LAR are available on the Bureau’s website. Regulation C provides sample language
that covered institutions can use for these purposes.24
Legal Status
The FR HMDA LAR is authorized pursuant to section 304(j) of HMDA (12 U.S.C.
2803(j)), which requires that the Bureau prescribe by regulation the form of loan application
register information that must be reported by covered financial institutions. Section 1003.5 of
Regulation C implements this statutory provision, and requires covered financial institutions to
submit reports to their appropriate federal agency. Section 304(h)(2)(A) of HMDA (12 U.S.C.
2803(h)(2)(A)) designates the Board as the appropriate agency with respect to the entities
described above. The FR HMDA LAR is mandatory.

24

See 12 CFR 1003.5(e).

7

HMDA requires the information collected on the FR HMDA LAR to be made available
to the general public in the form proscribed by the Bureau. The Bureau is authorized to redact or
modify the scope of the information before it is publicly disclosed to protect the privacy of loan
applicants and to protect depository institutions from liability under any federal or state privacy
law (12 U.S.C. 2803(j)(2)(B)). The redacted information may be kept confidential under
exemption 6 of the Freedom and Information Act, which protects from release information that,
if disclosed, would “constitute a clearly unwarranted invasion of personal privacy” (5 U.S.C.
552(b)(6)).
Consultation Outside the Agency
The Board consulted with the Bureau regarding the estimated burden of this information
collection. On August 28, 2018, the Board published an initial notice in the Federal Register
(83 FR 43868) requesting public comment for 60 days on the proposal to extend with revision,
the FR HMDA LAR. The comment period for this notice expired on October 29, 2018. The
Board did not receive any comments. On November 21, 2018, the Board published a final notice
in the Federal Register (83 FR 58773). The revisions will be implemented as proposed.
Estimate of Respondent Burden
The Board relied on the Bureau’s burden estimate methodology for all proposed burden
calculations herein.
For the purpose of calculating burden, the Bureau placed institutions into one of three
tiers, and the Board followed this approach. Tier 1 denotes an institution with the highest level
of complexity, tier 2 denotes a representative financial institution with a moderate level of
complexity, and tier 3 denotes a representative financial institution with the lowest level of
complexity.
The Bureau assumed that, for closed-end reporters, the tier 1 representative financial
institution has 50,000 records, the tier 2 representative has 1,000 records, and the tier 3
representative has 50 records on the HMDA LAR.
For open-end reporting, the Bureau adopted the three tier approach and most of the key
assumptions used for closed-end reporting above, with two modifications. First, for the
representative low-complexity open-end reporter, the Bureau assumed that the number of openend lines of credit applications would be 150. This was set to both accommodate the threshold
of 100 open-end lines of credit and to reasonably reflect the likely distribution among the
smallest open-end reporters based on the Bureau’s estimated number of likely open-end reporters
and their volumes. Second, for the representative high-complexity open-end reporter, the Bureau
assumed that the number of open-end line of credit applications would be 30,000. This reflects a
reasonable distribution among the largest open-end reporters based on the Bureau’s estimated
number of likely open-end reporters and their volumes. The Bureau assumed that the number of
open-end line of credit applications for the representative moderate-complexity open-end
reporter would still be 1,000, just as for the moderate-complexity closed-end reporter.

8

Current burden
Reporting
The Bureau considers most tasks that financial institutions undertake to gather and report
data as covered by the reporting requirements. Under the Bureau’s methodology, the reporting
requirements encompass transcribing data, resolving reportability questions, transferring data to
HMDA Management System (HMS), geocoding, standard annual edit and internal checks,
researching questions, resolving question responses, checking post-submission edits, filing postsubmission documents, creating public loan application register, distributing public loan
application register, distributing disclosure report, using vendor HMS software, training, internal
audits, external audits, exam preparation, and exam assistance. Therefore, the Bureau estimated
that tier 3, tier 2, and tier 1 financial institutions spend approximately 64 hours, 986 hours, and
4,182 hours per year meeting the reporting requirements, respectively.
Recordkeeping
Under the Bureau’s methodology, the recordkeeping requirement encompasses the
requirements that financial institutions maintain HMDA data for three years and disclosure
statements for five years, maintain loan application register information for three years, and
update information regarding reportable transactions quarterly. To maintain data, disclosure
statements, and loan application register information, the Bureau believes the primary time
burden is the time needed to copy this information to electronic data storage devices, such as a
hard drive or disk. The calculation of the burden hours for recordkeeping requirements is based
on the estimated cost of transcribing the data. The Bureau estimated that tier 3, tier 2, and tier 1
financial institutions spend approximately 8 hours, 83 hours, and 3,489 hours per year
transcribing data, respectively.
Disclosure
The calculation of burden hours for disclosure requirements is based on the estimated
cost of creating a modified LAR, distributing the modified loan/application register, and creating
the notice for obtaining the disclosure statements. The Bureau estimated that tier 3, tier 2, and
tier 1 financial institutions spend approximately 4 hours, 11 hours, and 26 hours per year,
respectively, meeting these requirements.
Proposed burden
Reporting
The Bureau estimated that annually-reporting tier 3, tier 2, and tier 1 financial institutions
would spend approximately 107 hours, 1,232 hours, and 5,969 hours per year meeting reporting
requirements, respectively. However, an institution that is eligible for the partial exemption
under section 104(a) of EGRRCPA is only required to report a subset of the data points required
under HMDA if it originates fewer than 500 closed-end mortgage loans in each of the two
preceding calendar years. For Board-supervised institutions, this partial exemption applies to all

9

Tier 3 institutions and a majority of the Tier 2 institutions (Tier 3 Crapo or Tier 2 Crapo,
respectively). For these institutions, the Board believes maintaining the current burden most
closely reflects the burden associated with this subset of data points.
Further, financial institutions with 60,000 covered loans and applications, combined,
excluding purchased covered loans, that will be required to report quarterly are tier 1
institutions. For these institutions, the Bureau estimated that it would require 934 burden hours
in addition to the proposed burden hours associated with annual reporting.
Recordkeeping
The calculation of the burden hours for recordkeeping requirements is based on the
estimated cost of transcribing the data. The Bureau estimated that tier 3, tier 2, and tier 1
financial institutions will spend approximately 27 hours, 83 hours, and 4,130 hours per year
transcribing data, respectively.
Disclosure
The calculation of burden hours for disclosure requirements is based on the estimated
cost of creating a modified loan/application register, distributing the modified loan/application
register, and creating the notice for obtaining the disclosure statements. The Bureau estimated
that tier 3, tier 2, and tier 1 financial institutions would spend approximately zero hours, zero
hours, and five hours per year, respectively, meeting these requirements. The estimated time
burden would be the same for quarterly reporters and annual reporters.
The current annual paperwork burden for the FR HMDA LAR is estimated to be 511,035
hours. The Board estimates that, with the proposed revisions, the total annual burden for the
institutions it supervises would increase to 673,474 hours, 88,880 hours of which are associated
with one-time burden, as shown in the table below. The current total burden for the
FR HMDA LAR represents 4.8 percent of total Federal Reserve System annual burden and with
the proposed revisions, which include one-time burden for purchasing or updating software
necessary to comply with the new rule, would increase to 6.3 percent of total Federal Reserve
System burden.

10

Number of
respondents25

FR HMDA LAR

Estimated
Estimated
Annual
average hours annual burden
frequency
per response
hours26

Current
Reporting
Tier 1
Tier 2
Tier 3
Recordkeeping
Tier 1
Tier 2
Tier 3
Disclosure
Tier 1
Tier 2
Tier 3

3
448
54

1
1
1

4,182
986
64

12,546
441,728
3,456

3
448
54

1
1
1

3,489
83
8

10,467
37,184
432

3
448
54

1
1
1

26
11
4

78
4,928
216
511,035

505

1

176

88,880

2
1
148
300
54

1
4
1
1
1

5,969
6,903
1,232
986
64

11,938
27,612
182,336
295,800
3,456

2
1

1
4

4,130
4,130

8,260
16,520

Total
Proposed
Update policies, procedures,
and systems (one-time)
Reporting
Tier 1 Annual Reporter
Tier 1 Quarterly Reporter
Tier 2
Tier 2 Crapo
Tier 3 Crapo
Recordkeeping
Tier 1 Annual Reporter
Tier 1 Quarterly Reporter
25

Of these respondents, 1 Tier 1 (annual) respondent, 259 Tier 2 respondents, and 44 Tier 3 respondents are
estimated to be small entities as defined by the Small Business Administration (i.e., entities with $550 million or less
in total assets) www.sba.gov/document/support--table-size-standards.
26
The estimates of proposed burden in the table include reporting of closed-end mortgage loans for all respondents
indicated in the number of respondents column, plus reporting of open-end lines of credit for the subset of
respondents that will also be required to report open-end lines of credit. The total burden per respondent in the table
is total burden divided by number of respondents, and therefore does not reflect the specific burden hours for either
respondents that report only closed-end mortgage loans or that report both closed-end mortgage loans and open-end
lines of credit.

11

Tier 2
Tier 3
Disclosure27
Tier 1: Annual Reporter
Tier 1: Quarterly Reporter

448
54

1
1

83
27

37,184
1,458

2
1

1
4

5
5

10
20
673,474
162,439

Total
Change

The current cost to the public28 is estimated to be $28,643,512 and with the proposed revisions is
estimated to increase to $37,748,218.29
Sensitive Questions
Institutions must generally request that applicants for covered loans provide information
about their sex, race, and ethnicity. For applications taken in person, the institution must
generally infer the information based on visual observation and surname if an applicant declines
to provide the information.30 The purpose of collecting this information is to assist in identifying
possible discriminatory lending patterns and enforcing anti-discrimination statutes.
Estimate of Cost to the Federal Reserve System
Effective January 2019, the Bureau is responsible for the collection of all HMDA data.
Therefore, the cost to the Federal Reserve System is considered negligible.

27

The Board estimates that the disclosure burden for Tier 2 and Tier 3 institutions is negligible.
All respondents of this information collection are considered to be the public.
29
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$69, 15% Lawyers at $68, and 10% Chief Executives at $94). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2017, published March 30, 2018 www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.
30
See 12 CFR 1003.4(b).
28

12