Comment Letter on the CFPB's ANPR Relating to Home Mortgage Disclosure (Regulation C) Data Points and Coverage

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Comment Letter on the CFPB's ANPR Relating to Home Mortgage Disclosure (Regulation C) Data Points and Coverage

Abstract

The Consumer Financial Protection Bureau is considering modifying or eliminating some of the Home Mortgage Disclosure Act data they began collecting from lenders in 2018. The researchers discuss the value of and burden of collecting data about land ownership in manufactured housing, disaggregated race/ethnicity, open format fields in loan denial and multifamily loans owned by corporate entities. They also discuss how some of the new data fields can be valuable to identifying risks in the housing finance system and informing better housing finance policy. Finally, the researchers suggest a few areas where increased disclosure would be very valuable.

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