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Loan Terms and Conditions Loan-to-Value Ratio (LTV) Rates Fixed Rate Adjustable Rate Conversion Term Full Term Loans (15, 30, etc.) Balloon Loans Amortization Full Amortization Interest Only Loans Reverse Equity Mortgages. Loan Terms and Conditions Loan-to-Value Ratio (LTV) Rates
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Loan Terms and Conditions Loan-to-Value Ratio (LTV) Rates • Fixed Rate • Adjustable Rate • Conversion Term • Full Term Loans (15, 30, etc.) • Balloon Loans Amortization • Full Amortization • Interest Only Loans • Reverse Equity Mortgages
Loan Terms and Conditions • Loan-to-Value Ratio (LTV) • Rates • Fixed Rate • Adjustable Rate • Conversion • Term • Full Term Loans (15, 30, etc.) • Balloon Loans • Amortization • Full Amortization • Interest Only Loans • Reverse Equity Mortgages
Exploring HMDA Analysis for Enforcement Activities HUD FHEO 2010 National Fair Housing Policy Conference Calvin Bradford Calvin Bradford & Associates, Ltd.
The Home Mortgage Disclosure Act (HMDA): • Provides public data on residential real estate loans by mortgage lenders • HMDA Provides Data on – • The Applicant and Co-Applicant • The Lender • The Loan Decision • Characteristics of the Loan • The Purpose and Type of Loan • The Property • The Lenders • The Location of the Loan.
Summary of HMDA Uses in Enforcement • Can Be Used to Identify Lenders for Investigation or Testing • Comparing Individual Lenders to A Selected Market • Defining Patterns that Would Be Consistent with (But Do Not Prove) Discrimination • To Identify Other Documents Related to Lending Patterns in the HMDA Data Analysis • Can Be Used to Investigate Individual Complaints • To Assist in Identifying Similarly Situated Applicants and Borrowers for Loan File Review • To Assist in Defining the Aspects of Lending (Marketing, Underwriting, Loan Channels, Etc.) Related to the Complaint • To Identify Other Documents Related to Lending Patterns in the HMDA Data Analysis
New HMDA Fields APPLICANT INFORMATION Age Credit Score (Range?) PROPERTY CHARACTERISTICS & DATA The Value of the Property A Property Parcel Number
New HMDA Fields LOAN CHARACTERISTICS Total Fees and Points More Detailed Benchmarks for Loan APRs Prepayment Penalties Term in Months of Introductory Rate Period Indication of Terms Not Providing for Amortization During Any Period of the Loan The Term in Months of the Loan
New HMDA Fields LOAN AND LENDER DATA A Universal Loan Identifier A Unique Loan Originator Identifier Designation of the Loan Channel (Retail, Broker, Etc.)