Personal Privacy of HMDA in a World of Big Data

When the Home Mortgage Disclosure Act was passed in 1975, it required selected depository institutions to report limited data from mortgage applications. This was collected and processed by the Federal Reserve Board in accordance with Regulation C. A subset of the reported information was then disclosed to the public. At the time, it was difficult to determine the identity of individual respondents in HMDA data. Since that time four things have changed. First, reporting requirements have been expanded to an increasing range of lenders. Second, the personal information reported and revealed has expanded. Third, over 30% of home purchases do not involve a HMDA reported mortgage and mortgage lending is increasingly internet based. Fourth, modern computing and big data techniques now allow the HMDA data releases to be matched with the names of individual borrowers in a fashion that violates standards for privacy established by the U.S. Bureau of the Census and appears to violate privacy standards of HMDA itself. Lack of privacy is particularly a problem for minority borrowers for whom the “risk†of re-identification is a virtual certainty.