We’ve received a lot of inquiries on what happened with the 2019 MSA codes: When will the pending 2019 demographic information changes be released? Has the 2018 HMDA Aggregate Data been announced? This “Special Delivery” will provide the most current information available to these questions.
New MSA Codes Confusion
In April 2018, OMB Bulletin No. 18-03 was released by the Office of Management and Budget (OMB) describing the revised delineations of the Nation’s Metropolitan Statistical Area (MSA) along with other statistical areas. It said that all agencies required to collect statistical information and publish MSA or other statistical area data should use the most recent OMB delineations. Here’s where the confusion exists: OMB released Bulletin No. 18-04 that corrected wrong MSA codes published in Bulletin #18-03, which resulted in the delay of new MSA codes being released on the FFIEC website until 2019.
Bulletin 18-04 contains the listing of all MSAs by alphabetical order along with the code for each area. Financial institutions should use OBM letter List 2 for current information. An example of the change is that the old code covering ChicagoNaperville-Arlington Heights, IL was 16974. The new MSA code is now 16984 for Chicago-Naperville-Evanston, IL. A question now arises: What happened to Arlington Heights, which was listed in the old MSA code name but is not listed in the new MSA code name? Arlington Heights was replaced with Evanston due to demographic changes in each city.
In 2019, banks utilizing the FFIEC’s geocoding process for HMDA and CRA reporting of an applicant’s address needed to start using the new MSA codes. There were no alerts or bulletins released by the FFIEC to notify bankers of the change. The only notification came from the OBM bulletins as noted above.
Banks should verify that their CRA and HMDA software are using MSAs from the September Bulletin No. 18-04.
FFIEC 2019 Demographic Information
Bankers using the FFIEC’s website to geocode addresses for HMDA and CRA purposes quickly realized that 2019 demographic information is not available as noted by the FFIEC in the following results box.
The demographic information provides information such as median family income, population data and housing data. TCA asked the FFIEC when the 2019 demographic information will be released. A spokesperson for the agency stated the information should be released in late summer, but no exact release date was provided.
TCA’s Special Release Articles will provide Alerts when relevant 2019 Demographic information is released.
2018 HMDA Aggregate Data
The Consumer Financial Protection Bureau (CFPB) was given oversight of Regulation C – Home Mortgage Disclosure Act in the Dodd-Frank Act. Under their authority, they added the collection of numerous data points and increased some of the exemption limits. Eligible filers submit HMDA reports to the CFPB. In 2018, the CFPB swiftly released the 2017 aggregate HMDA data; however, due to the revised data point collection changes effective in 2018, the 2018 aggregate information has not been released yet.
In late June, TCA asked the CFPB when the 2018 HMDA Aggregate data will be released. The CFPB confirmed no date has been set. You will hear from TCA as soon as the CFPB makes an announcement.
TCA recommends that banks performing fair lending self-testing utilize the most recent available information when conducting the peer analysis – which is 2017 data. Be sure to note the year of the peer data. Normally, the data percentages of the peers do not change significantly from one year to the next.
This update information should help you understand the obstacles you will encounter using HMDA and CRA data. If you have any question regarding these three issues, please contact TCA. In addition, if you need assistance with fair lending or CRA analyzes, please call to find out how TCA can provide A Better Way.
