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BUREAU OF CONSUMER FINANCIAL PROTECTION

PAPERWORK REDUCTION ACT SUBMISSION

INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A

HOME MORTGAGE DISCLOSURE (REGULATION C) 12 CFR 1003

(OMB CONTROL NUMBER: 3170-0008)

OMB TERMS OF CLEARANCE: 

None.

ABSTRACT: 

The Home Mortgage Disclosure Act (HMDA) requires most mortgage lenders lending in 

metropolitan areas to collect data about their housing-related lending activity. Annually, lenders 

must report those data to the appropriate federal agencies and make the data available to the 

public. The Consumer Financial Protection Bureau’s (CFPB) regulation requires covered 

financial institutions that meet certain thresholds to maintain data about home loan applications 

(e.g., the type of loan requested, the purpose of the loan, whether the loan was approved, and the 

type of purchaser if the loan was later sold), to update the information quarterly, and to report the 

information annually. The purpose of the information collection is: (i) to help determine whether 

financial institutions are serving the housing needs of their communities; (ii) to assist public 

officials in distributing public-sector investment so as to attract private investment to areas where 

it is needed; and (iii) to assist in identifying possible discriminatory lending patterns and 

enforcing antidiscrimination statutes. The information collection will assist the CFPB's 

examiners, and examiners of other federal supervisory agencies, in determining that the financial 

institutions they supervise comply with applicable provisions of HMDA.

PART A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

Data reported under the Home Mortgage Disclosure Act (HMDA), 12 U.S.C. 2801-2810, 

represent the primary data source for regulators, industry, advocates, researchers, and economists 

studying and analyzing trends in the mortgage market for a variety of purposes, including 

general market and economic monitoring, as well as assessing housing needs, public investment, 

and possible discrimination. Historically, HMDA has been implemented by Regulation C of the 

Board, 12 CFR 203, and HMDA data has been collected and reported under OMB control 

number 7100-0247. Congress has periodically modified the law, and the Board has routinely

updated Regulation C, in order to ensure that the data continued to fulfill the HMDA’s purposes. 
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Users of HMDA data, however, have consistently advocated for expansion of HMDA 

data to keep pace with the mortgage market’s evolution, particularly during the market’s rapid 

growth into nontraditional lending products and its subsequent collapse in 2008. In 2010, 

Congress responded to the mortgage crisis in the Dodd-Frank Act by enacting changes to HMDA 

as well as directing reforms to the mortgage market and the broader financial system. In addition 

to transferring rulemaking authority for HMDA from the Board to the Bureau, section 1094 of 

the Dodd-Frank Act directed the Bureau to implement changes requiring the collection and 

reporting of several new data points, and authorized the Bureau to require financial institutions to 

collect and report such other information as the Bureau may require.

HMDA requires financial institutions to report certain information related to covered 

loans. Financial institutions are required to report HMDA data annually to the Bureau or to the 

appropriate Federal agency. All reportable transactions must be recorded within 30 calendar 

days after the end of the calendar quarter in which final action is taken on a loan application 

register, which must also be disclosed to the public upon request. Financial institutions must 

also make their disclosure statements, which are prepared by the FFIEC from data submitted by 

the institutions, available to the public upon request.

The CFPB plans to issue a proposed rule to implement amendments to HMDA included

in the Dodd-Frank Act, and to make other changes in the CFPB’s Regulation C. The proposed 

rule would impose new reporting requirements by requiring financial institutions to report 

additional information required by the Dodd-Frank Act, as well as certain information 

determined by the Bureau to be necessary and proper to effectuate HMDA’s purposes. The 

proposed rule also modifies the scope of the institutional and transactional coverage thresholds. 

2. Use of the Information

The purpose of the information collection is: (1) to help determine whether financial 

institutions are serving the housing needs of their communities; (2) to assist public officials in 

distributing public-section investment so as to attract private investment to areas where it is 

needed; and (3) to assist in identifying possible discriminatory lending patterns and enforcing 

antidiscrimination statutes. The information collection will assist the CFPB’s examiners, and 

examiners of other federal supervisory agencies, in determining that the financial institutions 

they supervise comply with the applicable provisions of HMDA.

3. Use of Information Technology

All covered financial institutions regulated by the CFPB have the option to make the 

required disclosures electronically and most, if not all, disclose electronically.

4. Efforts to Identify Duplication

Substantially all of the information collected is not otherwise available. No privatelyproduced loan-level mortgage databases with comprehensive national coverage exist that are 

easily-accessible by the public. Private data vendors offer a few large databases for sale, but 
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these are typically collected via either the largest servicers or securitizers, and therefore none 

match the near-universal coverage of the HMDA data. Notably, unlike HMDA, almost all the 

commercially-available loan-level databases provided by vendors are for originated loans only 

and do not include applications that did not result in an origination.

5. Efforts to Minimize Burdens on Small Entities

The CFPB convened a Small Business Review Panel pursuant to the Small Business 

Regulatory Enforcement Fairness Act (SBREFA) to assess the potential impacts of that rule on 

such small entities. The CFPB has made improvements to certain elements of the proposal based 

on SBREFA feedback, such as commentary to address particular small entity representative

concerns. The CFPB has also incorporated the Panel recommendations and other SBREFA 

feedback into the preamble in order to solicit broader feedback from all stakeholders on issues 

raised by the SERs. However, the CFPB is not planning in the proposal to abandon any major 

element that was included in from the SBREFA outline in the proposal. This is consistent with 

the Panel Report, which did not recommend withdrawing any specific proposals. 

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction

HMDA provides for information to be collected annually. For large financial institutions 

engaging in 75,000 or more transactions, the CFPB is proposing a quarterly reporting 

requirement. The Bureau is concerned that less frequent reporting for the highest-volume 

institutions would impair the ability of the appropriate agencies to use HMDA data to effectuate 

the purposes of the statute in a timely manner. Furthermore, as quarterly reporting would require 

financial institutions with larger transaction volumes to edit smaller batches of reportable data 

several times throughout the year, the Bureau believes that quarterly reporting will facilitate and 

enhance compliance with HMDA, reduce reporting errors, and improve the quality of HMDA 

data. Finally, because quarterly reporting would permit the Bureau to process a significant 

volume of HMDA data throughout the year, the Bureau believes the proposal would allow for 

the earlier release to the public of HMDA data products, including the disclosure statements, 

aggregates and tables, and loan-level data currently released on the FFIEC website. 

7. Circumstances Requiring Special Information Collection

Regulation C requires financial institutions to retain and make available to the public the 

modified loan application register for a period of three years and the disclosure statement for a 

period of five years. These retention provisions are required by Congress, which provided in 

HMDA section 304(c) that information required to be compiled and made available under 

HMDA section 304, other than loan application register information required under section 

304(j), must be maintained and made available for a period of five years. HMDA section 

304(j)(6) requires that loan application register information for any year shall be maintained and 

made available, upon request, for three years.

8. Consultation Outside the Agency
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In preparing the notice of proposed rulemaking, the CFPB conducted outreach on 

implementing the Dodd-Frank Act amendments to HMDA and other potential changes to 

Regulation C by soliciting comments in Federal Register notices and by meeting with a variety 

of stakeholders, including trade associations, financial institutions, community groups, and other 

Federal agencies. The Bureau also convened a Small Business Review Panel to obtain feedback 

from small financial institutions as well as the general public. To prepare the proposal, the 

Bureau considered both the comments presented to the Board during its public hearings and 

feedback provided to the Bureau during its outreach.

The notice of proposed rulemaking was published in the Federal Register which provides 

the public 90 days to comment on the proposed rule, including the revised information collection 

requirements. Comments in response to this notice as well as CFPB’s response to those 

comments will be summarized in the preamble to the final rule.

9. Payments or Gifts to Respondents

Not applicable.

10. Assurances of Confidentiality

Respondents are financial institutions for which CFPB provides no assurances of 

confidentiality. The records kept under this collection are maintained by financial institutions 

and reported annually. Regulation C requires this information to be made available to the public 

except for three fields that are redacted to protect the identities of the individual applicants. The 

Bureau’s proposal would require that financial institutions release on the modified loan 

application register only the data that is currently released under Regulation C. 

11. Justification for Sensitive Questions

The information collection includes personally identifiable information regarding 

mortgage applicants or mortgagors. The information collected includes loan number and 

information that may indirectly identify an individual such as address, race/ethnicity, sex, annual 

income, and credit score associated with their mortgage. 

A system of records notice is not applicable because information is not retrieved by direct 

identifier.

Privacy impacts are evaluated throughout the proposed rule and specifically highlighted 

in Privacy Considerations under Part II.B and the discussion of the modified loan application 

register in Part V of the supplementary information. 

The information contains material that might be considered sensitive in nature, such as 

the race or national origin, gender, and income of loan applicants. When the information is 

disclosed to the public, it is redacted to omit the dates of application, dates of decisions on 

applications, and application numbers to prevent identification of individual applicants. 
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Additionally, the Bureau is proposing to “freeze” the modified loan application register so that it 

contains only the information currently reported under Regulation C. If the modified loan 

application register contains no new data points, the risk of the modified register interacting with 

the agencies’ loan-level release of those data in ways that create additional privacy risk is 

removed, providing the agencies with increased flexibility to apply any necessary privacy 

protections in a way that maximizes utility of the loan-level data to users and to adjust those 

protections as risks evolve.

12. Estimated Burden of Information Collection

Hours: 

The CFPB estimates that the reporting, ongoing recordkeeping, and third party disclosure 

requirement costs allocated to the CFPB under Regulation C is currently approximately 

1,787,000 hours per year, excluding the proposed changes. Including the proposed changes and 

operations modernization, the time burden for annual and quarterly CFPB reporters would be 

1,694,000 and 183,000 hours per year, respectively, for a total estimate of 1,877,000 burden 

hours per year. This represents an increase of approximately 90,000 burden hours per year for 

HMDA reporters that report to the CFPB. The Bureau estimates that, including the proposed 

changes, the proposed burden would be approximately 4,654,000 hours per year for all HMDA 

reporters.

1 This represents an increase of approximately 311,000 hours per year over the current 

burden for all HMDA reporters of 4,343,000 hours.

This proposed rule has three Information Collections under the PRA: (1) Reporting 

Requirements, (2) Recordkeeping Requirements, and (3) Third Party Disclosure Requirements 

Each of these Information Collections is discussed in turn. 

Given that HMDA is a data collection statute, the Bureau views most tasks that financial 

institutions undertake to gather and report data as covered by the Reporting Requirements. 

Based on initial outreach efforts, the Bureau identified 18 tasks that financial institutions conduct 

when gathering and reporting data under HMDA2. These outreach efforts also determined that 

the time and monetary cost of conducting these 18 tasks differed by financial institutions’ level 

of complexity. To capture the relationships between institutions’ complexity and reporting costs 

for each of these 18 tasks, the Bureau developed three representative financial institutions 

reflecting low-, moderate- and high-complexity. (In the following discussion, these are referred 

to as tier 3, 2, and 1 financial institutions respectively.) For the PRA burden analysis, we 

estimated the time each of the three representative lenders spend on each of the 18 tasks. We 

 1 The Bureau estimates that, for all HMDA reporters, the burden hours will be approximately 3,356,000 to 5,953,000 

hours per year. 4,654,000 is approximately the mid-point of this estimated range. 2 These are 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 post-submission 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, exam assistance, training, internal audits, and external audits.
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then took these institution-level estimates and aggregated up to the market level. All of these 

time estimates assume all aspects of the proposed rule, as well as the operations modernization

improvements being separately considered, will be adopted.

The Reporting Requirement covers 14 of the 18 operational tasks.3 Four of these 14

operational tasks are variable-cost tasks, which vary by the number of applications.4 With all the 

proposed changes and operational modernization, we estimate that tier 3, tier 2, and tier 1 

financial institutions spend approximately 26, 67, and 371 hours per year, respectively, on these 

four tasks. The estimated hours spent on these four variable tasks will be the same for annual 

and quarterly reporters, because the proposed adoption of quarterly reporting does not affect any 

of the variable cost tasks. For the ten fixed-cost operational tasks covered by the Reporting 

Requirements, we estimate that tier 3, tier 2, and tier 1 financial institutions required to report 

annually spend approximately 36, 593, and 4,777 hours per year, respectively, on these tasks. 

Financial institutions with 75,000 or more transactions that would be required to report quarterly 

are most likely tier 1 institutions. For these institutions, we estimate 669 burden hours in 

addition to the burden hours associated with annual reporting. Combining these results yields 

estimates of 63, 660, and 5,148 hours per year that tier 3, 2, and 1 annually-reporting financial 

institutions spend to gather and report data under HMDA each year. The estimated burden hours 

for quarterly-reporting financial institutions are approximately 5,817 hours per year.

In 2012, 197 financial institutions reported HMDA data to the CFPB. These 197 financial 

institutions are depository institutions with over $10 billion in assets.

5

 Given their large asset 

size, these depository institutions are likely comparable to the representative tier 1 institution. 

Therefore, to calculate burden hours, we assume that all 197 financial institutions that reported 

HMDA data to the CFPB are tier 1 institutions. Eighteen of these 197 institutions reported over 

75,000 loan application register records, and would therefore be required to report data quarterly. 

We estimate that the time burden for annual and quarterly reporters under the Reporting 

Requirements Information Collection would be approximately 921,000 and 105,000 hours per 

year, respectively, for a total estimated burden hours of 1,026,000 per year.

 3 These are resolving reportability questions, transferring data to HMDA Management System (HMS), geocoding, 

standard annual edit and internal checks, researching questions, resolving question responses, checking postsubmission edits, filing post-submission documents using vendor HMS software, training, internal audits, external 

audits, exam preparation, exam assistance, training, internal audits, and external audits. As discussed below, 

transcribing data falls under the record keeping requirement, and creating the public LAR, distributing the public 

LAR, and creating the notice for obtaining the disclosure statement all fall under the Third Party Disclosure 

Requirement. 

4 The four variable cost tasks are transferring data to HMS, resolving reportability questions, geocoding, and 

researching questions.

5 Note even though CFPB had supervisory authority over all non-depository institutions on all consumer financial 

protection related matter, nondepository institutions report HMDA data to HUD.
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Total Burden, Reporting Requirements-Financial Institutions Reporting to the CFPB

Number of 

Respondents

Total Burden 

per 

Respondent

Total

Burden 

(Rounded to 

Thousands)

Tier One: Annual Reporter 179 5,148 hours 921,000 hours

Tier One: Quarterly Reporter 18 5,817 hours 105,000 hours

Tier Two 0 660 hours 0 hours

Tier Three 0 63 hours 0 hours

Total Estimated Burden for CFPB Respondents 1,026,000 hours

The Record Keeping Requirement covers 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 primary time burden is the time needed to copy this information to electronic 

data storage devices, such as a hard drive or disk. Given the prevalence and low cost of modern 

computer technology, The Bureau believes that this time burden is negligible. We regard the 

task of transcribing data as the key operational task that is directly related to recordkeeping. This 

task is not affected by whether the financial institution is required to report annually or quarterly, 

since transcribing data for reportable transactions under HMDA is not affected by reporting 

frequency. We calculate the burden hours for record keeping requirement based on the estimated 

cost of transcribing the data. The Bureau estimates that tier 3, tier 2, and tier 1 financial 

institutions would spend approximately 19, 86, and 4,277 hours per year transcribing data, 

respectively. 

Total Burden, Recordkeeping Requirements-Financial Institutions Reporting to the CFPB

Number of 

Respondents

Total Burden 

per 

Respondent

Total

Burden

(Rounded to 

Thousands)

Tier One: Annual Reporter 179 4,277 hours 766,000 hours

Tier One: Quarterly Reporter 18 4,277 hours 77,000 hours

Tier Two 0 86 hours 0 hours

Tier Three 0 19 hours 0 hours

Total Estimated Burden for CFPB Respondents 843,000 hours

The Third Party Disclosure Requirement covers the requirements that financial 

institutions create a public loan application register, distribute the public loan application register 
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upon request, and provide a notice that the disclosure statement can be obtained from the FFIEC 

website. These requirements correspond to three operational tasks: creating the public loan 

application register, distributing the public loan application register, and creating the notice for 

obtaining the disclosure statement. The Bureau estimates that tier 3, tier 2, and tier 1 financial 

institutions would spend approximately 8, 18, and 40 hours per year, respectively, on these 

operational tasks. All financial institutions would conduct all of these steps, so the estimated 

time burden would be the same for quarterly reporters and annual reporters. 

Total Burden, Third Party Disclosure Requirements-Financial Institutions Reporting to

the CFPB

Number of 

Respondents

Total Burden 

per 

Respondent

Total

Burden

(Rounded to 

Thousands)

Tier One: Annual Reporter 179 40 hours 7,000 hours

Tier One: Quarterly Reporter 18 40 hours 1,000 hours

Tier Two 0 18 hours 0 hours

Tier Three 0 8 hours 0 hours

Total Estimated Burden for CFPB Respondents 8,000 hours

Combining the three Information Collections, the Bureau estimates that the total burden 

hours for financial institutions required to report HMDA data to the CFPB is approximately 

1,877,000.

To estimate the burden hours for all HMDA reporters, we follow the mapping approach 

used for the discussion of the potential benefits, costs, and impacts of the proposed rule, 

described in Section VI of the supplementary information. Specifically, we allocate financial 

institutions across tiers using the two distributions described in the benefit-cost discussion to 

provide upper and lower bounds for our estimates.6 After assigning each of the 7,400 HMDA 

reporters7 to a tier using the two distributions, we then make two adjustments. First, we adjust 

the number of financial institutions to account for the estimated 1,600 depository institutions that 

would no longer be required to report under the proposed coverage changes, as well as the 450 

nondepository institutions that would have to begin reporting. Given the small volume of 

transactions processed by these financial institutions, we assume all financial institutions 

described under the first adjustment are most closely comparable to a representative tier 3 

institution. Therefore, we reduce the number of tier 3 financial institutions by 1,150. Second, in 

the 2012 HMDA data, 28 financial institutions submitted a HMDA loan application register with 

75,000 or more records, and would therefore be required to report quarterly. Given the high 

 6 The first distribution assumes the following composition among financial institutions: 96% tier 3, 0% tier 2, and 

4% tier 1. The second distribution assumes the following composition among financial institutions: 31% tier 3, 66% 

tier 2, and 3% tier 1.

7 The estimate of 7400 HMDA reporters is derived from the 2012 HMDA data.
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volume of transactions reported by these financial institutions, they are likely to be most closely 

comparable to the representative tier 1 financial institution. We therefore separately itemize the 

burden hour estimates for tier 1 financial institutions that would be required to report quarterly. 

Using both the distribution assumptions and the institution-level hour estimates described above, 

we estimate that the time burden for all institutions to gather and report data under HMDA is 

approximately 3,400,000 to 6,000,000 hours per year. The mid-point of this range is 

approximately 4,700,000.

Total Burden, all Information Collections- All Regulated Entities

Lower Bound Estimate Upper Bound Estimate

Number of 

Respondents

Total 

Burden per 

respondent

Total

Burden

(Rounded to 

Thousands)

Number of 

Respondents

Total 

Burden per 

respondent

Total

Burden

(Rounded to 

Thousands)

Tier One

Annual 

Reporter

268 9,464

hours

2,536,000

hours

194 9,464

hours

1,836,000

hours

Tier One 

Quarterly 

Reporter

28 10,133

hours

284,000 hours 28 10,133 

hours

284,000 hours

Tier Two 0 764 hours 0 hours 4,884 764 hours 3,730,000

hours

Tier 

Three

5954 90 hours 536,000 hours 1,144 90 hours 103,000 hours

Total Estimated Burden for all Respondents (Rounded to 100 Thousands) 

4,700,000 hours8

Associated Labor Costs: 

To estimate the associated labor costs, we use the burden hours described above, along 

with a wage rate of $28 per hour, which is the national average wage for compliance officers 

based on most recent National Compensation Survey from the Bureau of Labor Statistics (BLS). 

Based on these figures, the Bureau estimates that the ongoing record keeping and reporting costs 

allocated to the CFPB under Regulation C is approximately $52,500,000. For all HMDA 

reporters, the estimated costs are between $130,000,000.

9

 

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers 

 8 The Bureau estimates that, for all HMDA reporters, the burden hours will be approximately 3,400,000 to 6,000,000 

hours per year. 4,700,000 is approximately the mid-point of this estimated range. 9 The Bureau estimates that the labor costs will be approximately $94,000,000 to $167,000,000. $130,000,000 is the 

mid-point of this estimated range.
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The non-labor-specific costs specific to complying with the Reporting, Recordkeeping,

and Third Party Disclosure Requirements include the annual fee for HMS software, and the 

annual fee for the LEI. The Bureau estimates that this annual fee for HMS software is 

approximately $0 for tier 3 institutions, $8,000 for tier 2 institutions and $13,000 for tier 1 

institutions The estimated annual fee for the LEI is approximately $200. Therefore, the total 

estimated cost is $2,600,000 for CFPB-regulated entities and $24,200,000 for all regulated 

entities.

10 

14. Estimated Cost to the Federal Government

There are no additional costs to the Federal Government.

15. Program Changes or Adjustments

Summary of Burden Changes

Burden Hours Cost Burden (O & M)

Total Annual Hours 

Requested

1,877,000 Total Annual Costs Burden 

Requested

$2,600,000

Current OMB Inventory 154,000 Current OMB Inventory 0

Difference (+/-) +1,723,000 Difference (+/-) +$2,600,000

Program Change 87,600 Program Change $2,500,000

Discretionary 34,400 Discretionary $965,000

Due to New Statute 53,200 Due to New Statute $1,500,000

Violation 0 Violation 0

Adjustment 1,635,400 Adjustment $100,000

16. Plans for Tabulation, Statistical Analysis, and Publication

The information is collected for use by the CFPB’s examination program and for 

disclosure to the public after deletion of certain sensitive data elements.

17. Display of Expiration Date

The OMB number will be displayed in the PRA section of the notice of final rulemaking 

and in the codified version of the Code of Federal Regulations. Further, the OMB control 

number and expiration date will be displayed on the Federal government’s electronic PRA 

docket at www.reginfo.gov.

18. Exceptions to the Certification Requirement

The Bureau certifies that this collection of information is consistent with the requirements 

 10 The Bureau estimates that the annual non-labor costs will be approximately $5,100,000 to $43,200,000. 

$24,200,000 is the mid-point of this estimated range.
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of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is not seeking an 

exemption to these certification requirements.