Designated Key HMDA Data Fields

The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation 

(FDIC), and the Office of the Comptroller of the Currency (OCC) are issuing designated key HMDA data 

fields to support the efficient and effective evaluation of financial institutions’ compliance with HMDA’s 

requirements. 

The Home Mortgage Disclosure Act (HMDA), which is implemented by Regulation C, 12 C.F.R. 1003, 

requires certain financial institutions to collect, record, and report information about their mortgage 

lending activity.1

 Amendments to Regulation C (HMDA Amendments)2 establish the data to be 

collected.3

 For the purpose of ensuring compliance with HMDA’s requirements, traditionally the FRB, 

the FDIC, and the OCC have identified and focused examination-related testing of HMDA data on certain 

agency-designated “key fields.” Key fields are those fields considered to be most important to ensuring 

the integrity of analyses of overall HMDA data. 

Separately, the Federal Financial Institutions Examination Council (FFIEC) members have issued FFIEC 

HMDA Examiner Transaction Testing Guidelines (Guidelines) for the FFIEC members’ examination staff 

to use in assessing the accuracy of the HMDA data that financial institutions record and report.4

 The 

Guidelines include a data sampling process that involves prioritizing designated data fields for review or 

reviewing all data fields within a sample. However, the Guidelines themselves do not establish 

designated key data fields. In an effort to promote efficiency, coordination, and consistency, the FRB, 

FDIC, and OCC have jointly identified and designated 37 of the HMDA data fields to be collected 

beginning January 1, 2018, pursuant to the HMDA Amendments, as Designated Key HMDA Data Fields. 

In identifying Designated Key HMDA Data Fields, the FRB, FDIC, and OCC considered a variety of factors, 

including HMDA’s requirements, the goal of ensuring the efficiency of bank examinations, and the 

effective validation of HMDA data important to evaluating compliance with the Community 

Reinvestment Act and fair lending requirements. The FRB, FDIC, and OCC also took into account the 

likelihood that a data field would be reported correctly based on past examination experience. 

Accordingly, for the purpose of evaluating financial institutions’ compliance with HMDA requirements, 

FRB, FDIC, and OCC examination staffs will focus primary attention on the Designated Key HMDA Data 

Fields during transaction testing pursuant to HMDA for data collected on or after January 1, 2018.5

 

However, in certain circumstances, consistent with the FFIEC Guidelines, such examination staff may 

determine that it is necessary to review additional HMDA data fields, as appropriate. 

 

1 12 U.S.C. 2801 et seq. 2 80 FR 66127 (Oct. 28, 2015), as further amended. 

3 Beginning with data collected on or after January 1, 2018, financial institutions subject to HMDA will collect and report data 

on covered loans specified in 12 C.F.R. 1003.4(a)(1)-(38) on a loan application register containing 110 “data fields,” as specified 

in the FFIEC Filing Instructions Guide (FIG). The FIG is available on the FFIEC webpage or on the Consumer Financial Protection 

Bureau (CFPB) webpage. 4 The FFIEC members are the FRB, the FDIC, the OCC, the CFPB, the National Credit Union Administration, and the State Liaison 

Committee. The FFIEC members promote compliance with federal consumer protection laws and regulations through 

supervisory and outreach programs. Among these laws and regulations is HMDA. 5 Each agency shall operate in accordance with its supervisory authority.
2 

All 110 data fields are listed in the table below. Designated Key HMDA Data Fields are shown in 

italicized bold text. 

# Data Field Name Data Point Name

1 Record Identifier – Value is 2

2 Legal Entity Identifier (LEI) Legal Entity Identifier (LEI)

3 Universal Loan Identifier (ULI) Universal Loan Identifier (ULI)

4 Application Date Application Date

5 Loan Type Loan Type

6 Loan Purpose Loan Purpose

7 Preapproval Preapproval

8 Construction Method Construction Method

9 Occupancy Type Occupancy Type

10 Loan Amount Loan Amount

11 Action Taken Action Taken

12 Action Taken Date Action Taken Date 

13 Street Address Property Address

14 City Property Address

15 State Property Location & Property 

Address

16 Zip Code Property Address

17 County Property Location 

18 Census Tract Property Location 

19 Ethnicity of Applicant or Borrower: 1 Ethnicity

20 Ethnicity of Applicant or Borrower: 2 Ethnicity

21 Ethnicity of Applicant or Borrower: 3 Ethnicity

22 Ethnicity of Applicant or Borrower: 4 Ethnicity

23 Ethnicity of Applicant or Borrower: 5 Ethnicity

24 Ethnicity of Applicant or Borrower: Free Form Text Field for 

Other Hispanic or Latino

Ethnicity

25 Ethnicity of Co-Applicant or Co-Borrower: 1 Ethnicity

26 Ethnicity of Co-Applicant or Co-Borrower: 2 Ethnicity

27 Ethnicity of Co-Applicant or Co-Borrower: 3 Ethnicity

28 Ethnicity of Co-Applicant or Co-Borrower: 4 Ethnicity

29 Ethnicity of Co-Applicant or Co-Borrower: 5 Ethnicity

30 Ethnicity of Co-Applicant or Co-Borrower: Free Form Text 

Field for Other Hispanic or Latino

Ethnicity

31 Ethnicity of Applicant or Borrower Collected on the Basis of 

Visual Observation or Surname

Ethnicity

32 Ethnicity of Co-Applicant or Co-Borrower Collected on the 

Basis of Visual Observation or Surname

Ethnicity

33 Race of Applicant or Borrower: 1 Race
3 

# Data Field Name Data Point Name

34 Race of Applicant or Borrower: 2 Race

35 Race of Applicant or Borrower: 3 Race

36 Race of Applicant or Borrower: 4 Race

37 Race of Applicant or Borrower: 5 Race

38 Race of Applicant or Borrower: Free Form Text Field for 

American Indian or Alaska Native Enrolled or Principal Tribe

Race

39 Race of Applicant or Borrower: Free Form Text Field for Other 

Asian

Race

40 Race of Applicant or Borrower: Free Form Text Field for Other 

Pacific Islander

Race

41 Race of Co-Applicant or Co-Borrower: 1 Race

42 Race of Co-Applicant or Co-Borrower: 2 Race

43 Race of Co-Applicant or Co-Borrower: 3 Race

44 Race of Co-Applicant or Co-Borrower: 4 Race

45 Race of Co-Applicant or Co-Borrower: 5 Race

46 Race of Co-Applicant or Co-Borrower: Free Form Text Field 

for American Indian or Alaska Native Enrolled or Principal 

Tribe

Race

47 Race of Co-Applicant or Co-Borrower: Free Form Text Field 

for Other Asian

Race

48 Race of Co-Applicant or Co-Borrower: Free Form Text Field 

for Other Pacific Islander

Race

49 Race of Applicant or Borrower Collected on the Basis of Visual 

Observation or Surname

Race

50 Race of Co-Applicant or Co-Borrower Collected on the Basis 

of Visual Observation or Surname

Race

51 Sex of Applicant or Borrower Sex

52 Sex of Co-Applicant or Co-Borrower Sex

53 Sex of Applicant or Borrower Collected on the Basis of Visual 

Observation or Surname

Sex

54 Sex of Co-Applicant or Co-Borrower Collected on the Basis of 

Visual Observation or Surname

Sex

55 Age of Applicant or Borrower Age

56 Age of Co-Applicant or Co-Borrower Age

57 Income Income

58 Type of Purchaser Type of Purchaser

59 Rate Spread Rate Spread

60 HOEPA Status HOEPA Status

61 Lien Status Lien Status

62 Credit Score of Applicant or Borrower Credit Score

63 Credit Score of Co-Applicant or Co-Borrower Credit Score
4 

# Data Field Name Data Point Name

64 Applicant or Borrower, Name and Version of Credit Scoring 

Model

Credit Score

65 Applicant or Borrower, Name and Version of Credit Scoring 

Model: Conditional Free Form Text Field For Code 8

Credit Score

66 Co-Applicant or Co-Borrower, Name and Version of Credit 

Scoring Model

Credit Score

67 Co-Applicant or Co-Borrower, Name and Version of Credit 

Scoring Model: Conditional Free Form Text Field For Code 8

Credit Score

68 Reason for Denial: 1 Reason for Denial

69 Reason for Denial: 2 Reason for Denial

70 Reason for Denial: 3 Reason for Denial

71 Reason for Denial: 4 Reason for Denial

72 Reason for Denial: Conditional Free Form Text Field for Code 

9 

Reason for Denial

73 Total Loan Costs Total Loan Costs or Total Points 

and Fees

74 Total Points and Fees Total Loan Costs or Total Points 

and Fees

75 Origination Charges Origination Charges

76 Discount Points Discount Points

77 Lender Credits Lender Credits

78 Interest Rate Interest Rate

79 Prepayment Penalty Term Prepayment Penalty Term 

80 Debt-to-Income Ratio Debt-to-Income Ratio

81 Combined Loan-To-Value Ratio Combined Loan-To-Value Ratio

82 Loan Term Loan Term

83 Introductory Rate Period Introductory Rate Period

84 Balloon Payment Non-Amortizing Features

85 Interest-Only Payments Non-Amortizing Features

86 Negative Amortization Non-Amortizing Features

87 Other Non-Amortizing Features Non-Amortizing Features

88 Property Value Property Value

89 Manufactured Home Secured Property Type Manufactured Home Secured 

Property Type

90 Manufactured Home Land Property Interest Manufactured Home Land 

Property Interest

91 Total Units Total Units

92 Multifamily Affordable Units Multifamily Affordable Units 

93 Submission of Application Application Channel

94 Initially Payable to Your Institution Application Channel
5 

# Data Field Name Data Point Name

95 Mortgage Loan Originator NMLSR Identifier Mortgage Loan Originator 

NMLSR Identifier

96 Automated Underwriting System: 1 Automated Underwriting 

System

97 Automated Underwriting System: 2 Automated Underwriting 

System

98 Automated Underwriting System: 3 Automated Underwriting 

System

99 Automated Underwriting System: 4 Automated Underwriting 

System

100 Automated Underwriting System: 5 Automated Underwriting 

System

101 Automated Underwriting System: Conditional Free Form Text 

Field for Code 5

Automated Underwriting 

System 

102 Automated Underwriting System Result: 1 Automated Underwriting 

System

103 Automated Underwriting System Result: 2 Automated Underwriting 

System

104 Automated Underwriting System Result: 3 Automated Underwriting 

System

105 Automated Underwriting System Result: 4 Automated Underwriting 

System

106 Automated Underwriting System Result: 5 Automated Underwriting 

System

107 Automated Underwriting System Result: Conditional Free 

Form Text Field for Code 16

Automated Underwriting 

System 

108 Reverse Mortgage Reverse Mortgage

109 Open-End Line of Credit Open-End Line of Credit

110 Business or Commercial Purpose Business or Commercial 

Purpose