Designated Home Mortgage Disclosure Act (HMDA) Key Data Fields

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

Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) have designated 

HMDA key 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 The Bureau of Consumer Financial Protection’s (Bureau) 

amendments to Regulation C (HMDA Amendments)2

 and section 104(a) of the Economic 

Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA)3 establish the data to be 

collected.4

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

the Board, 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 data fields 

considered to be most important to ensuring the integrity of analyses of overall HMDA data. 

Separately, the FFIEC members have issued FFIEC HMDA Examiner Transaction Testing 

Guidelines (FFIEC Guidelines) for the FFIEC members’ examination staffs to use in assessing 

the accuracy of the HMDA data that financial institutions collect, record, and report.5 The 

FFIEC Guidelines include a data sampling process that involves prioritizing designated data 

fields for review or reviewing all data fields within a sample.

However, the FFIEC Guidelines themselves do not establish designated HMDA key data fields. 

In an effort to promote efficiency, coordination, and consistency, the Board, the FDIC, and the

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

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

For institutions eligible for a partial exemption pursuant to EGRRCPA,6 21 of the 37 Designated 

 

1 12 U.S.C. 2801 et seq. 2 80 FR 66127 (October 28, 2015); 82 FR 43088 (September 13, 2017). 

3 132 Stat. 1296 (2018), section 104(a) (codified at 12 U.S.C. 2803).

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

report data on covered loans specified in 12 C.F.R. § 1003.4(a)(1)-(38) on a loan application register (LAR) 

containing 110 “data fields,” as specified in the applicable Federal Financial Institutions Examination Council 

(FFIEC) Filing Instructions Guide (FIG), available through the FFIEC HMDA File Specifications webpage at 

https://www.ffiec.gov/hmda/fileformats.htm or with other FFIEC HMDA resources at https://ffiec.cfpb.gov/. 5 The FFIEC members are the Board, the Bureau, the FDIC, the National Credit Union Administration, the OCC, 

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. 6 Provided that they are not subject to the exception to the partial exemptions for adverse Community Reinvestment 

Act (CRA) examination history, insured depository institutions eligible for a partial exemption are not required to 

collect, record, and report certain HMDA data points specified in EGRRCPA, as further explained in the Bureau’s 

interpretive and procedural rule to clarify and implement the legislation (83 FR 45325 (September 7, 2018)). 

Various HMDA data points are associated with multiple HMDA data fields. Financial institutions subject to a 

partial exemption also collect and report their HMDA data, on a LAR, as specified in the applicable FIG. 
2 

HMDA Key Data Fields are among the data fields that they remain responsible for collecting, 

recording, and reporting. In identifying Designated HMDA Key Data Fields, the Board, the 

FDIC, and the 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 CRA and fair lending requirements. The Board, the 

FDIC, and the 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, the Board, the FDIC, and the OCC will focus primary attention on the Designated 

HMDA Key Data Fields during transaction testing for HMDA data collected on or after January 

1, 2018.7 However, in certain circumstances, consistent with the FFIEC Guidelines, examination 

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

Table 1 lists all 110 HMDA data fields and their corresponding HMDA data points. The 37 

Designated HMDA Key Data Fields applicable to financial institutions not eligible for an 

EGRRCPA partial exemption from HMDA’s data collection, recording, and reporting 

requirements are shown in italicized bold text. The 21 Designated HMDA Key Data Fields

applicable to financial institutions that are eligible for an EGRRCPA partial exemption from 

HMDA’s data collection, recording, and reporting requirements are identified by an asterisk (*).

Table 2 solely lists the 37 Designated HMDA Key Data Fields (Column B) applicable to

financial institutions not eligible for an EGRRCPA partial exemption from HMDA’s data 

collection, recording, and reporting requirements and, separately, the 21 Designated HMDA Key 

Data Fields (Column C) applicable to financial institutions that are eligible for an EGRRCPA 

partial exemption from HMDA’s data collection, recording, and reporting requirements. 

 

Furthermore, as indicated in the Bureau’s interpretive and procedural rule, institutions eligible for a partial 

exemption may nevertheless opt to report HMDA data covered by that partial exemption. 7 Each agency shall operate in accordance with its supervisory authority.
3 

Table 1

# 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)

or Non-Universal Loan Identifier (NULI)

Universal Loan Identifier 

(ULI) or Non-Universal 

Loan Identifier (NULI)

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*
4 

# 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
5 

# 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 
6 

# Data Field Name Data Point Name

93 Submission of Application Application Channel

94 Initially Payable to Your Institution Application Channel

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
7 

Table 2

A

# 

B

Designated Key HMDA Data Fields 

for financial institutions not eligible 

for an EGRRCPA partial exemption 

from HMDA data collection, 

recording, and reporting requirements

C

Designated Key HMDA Data Fields for 

financial institutions that are eligible for 

an EGRRCPA partial exemption from 

HMDA data collection, recording, and 

reporting requirements

3 Universal Loan Identifier (ULI)

4 Application Date Application Date

5 Loan Type Loan Type

6 Loan Purpose Loan Purpose

9 Occupancy Type Occupancy Type

10 Loan Amount Loan Amount

11 Action Taken Action Taken

12 Action Taken Date Action Taken Date

18 Census Tract Census Tract

19 Ethnicity of Applicant or Borrower: 1 Ethnicity of Applicant or Borrower: 1

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

33 Race of Applicant or Borrower: 1 Race of Applicant or Borrower: 1

34 Race of Applicant or Borrower: 2 Race of Applicant or Borrower: 2

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

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

51 Sex of Applicant or Borrower Sex of Applicant or Borrower

52 Sex of Co-Applicant or Co-Borrower Sex of Co-Applicant or Co-Borrower

55 Age of Applicant or Borrower Age of Applicant or Borrower

56 Age of Co-Applicant or Co-Borrower Age of Co-Applicant or Co-Borrower

57 Income Income

61 Lien Status Lien Status

62 Credit Score of Applicant or Borrower

63 Credit Score of Co-Applicant or Co-Borrower

75 Origination Charges

76 Discount Points

77 Lender Credits

78 Interest Rate

80 Debt-to-Income Ratio

81 Combined Loan-To-Value Ratio

82 Loan Term

88 Property Value

89 Manufactured Home Secured Property Type

91 Total Units Total Units

102 Automated Underwriting System Result: 1

108 Reverse Mortgage

109 Open-End Line of Credit

110 Business or Commercial Purpose