At least eight databases and other “core data assets” are maintained or accessible to the federal consumer financial protection agency – including financial institution call reports, supervisory activities data and more – according to a report issued Tuesday by the agency.
Also among the data sources, according to the report: a credit card database. However, the Bureau of Consumer Financial Protection (BCFP, formerly known as the CFPB) indicated the data source does not contain transaction-level data pertaining to consumer purchases.
The BCFP report – Sources and Uses of Data at the Bureau of Consumer Financial Protection – is intended to describe the data collected by the agency, where the data comes from, and how the data is accessed and reused within the BCFP. The report also outlines the full text of the agency’s internal data governance policies and charters, the agency said in a release.
The seven databases are among a wide variety of data sources outlined in the report, which accompanied a “request for information” (RFI) from the agency (also issued Tuesday) seeking public comment about sources for data and how the information is used by the bureau. Comments are due in 90 days.
However, the seven databases outlined in the report indicate the broad reach of the agency in collecting data regarding consumer financial issues. The seven databases outlined in the report are:
- Consumer complaints: Includes consumer descriptions of their issues with companies providing financial products or services. Complaint data is also received in the form of company responses to those consumers. It also receives inquiries and feedback from consumers.
- Enforcement activities data: Collected in the course of enforcement activities. It is not one data asset, but a number of data assets maintained separately for each enforcement matter, each with access restrictions. Data are considered confidential investigative information (CII), and are governed by regulation and bureau requirements regarding CII. If any of these data are shared with the bureau’s division of Research, Markets, and Regulations (RMR), access restrictions apply to such data.
- Supervisory activities data: Data collected in the course of supervisory activities. Also not one data asset, but a number of data assets maintained separately for each supervisory matter, each with access restrictions. These data are considered confidential supervisory information (CSI) and are governed by regulation and agency requirements regarding CSI. If any of these data are shared with RMR, access restrictions apply to the data.
- Consumer Credit Panel (CCP): A nationally representative panel (1 in 48 sample) of approximately 5 million de-identified consumer credit records updated monthly, dating back to 2001. The bureau said it procured the data through a “competitive procurement process” from one of the three nationwide credit reporting agencies (each of sells data). The CCP data also includes marketing data (such as estimated income) which the bureau said its vendor sells for marketing purposes. The CCP excludes direct identifiers and the vendor does not provide the name of the lender, or other furnisher of data contained in the vendor’s records, but instead provides a unique identifier for each data furnisher, according to the agency.
- National Mortgage Database (NMDB): A joint project with the Federal Housing Finance Agency (FHFA), it is a source of information about the U.S. mortgage market based on a 5% sample of residential mortgages. It consists of three primary components: (1) account-level origination and loan performance data along with credit information associated with the accounts; (2) the quarterly National Survey of Mortgage Originations (NSMO); and (3) the annual American Survey of Mortgage Borrowers (ASMB). The bureau said that to construct the NMDB, one of the three nationwide consumer reporting agencies provides quarterly mortgage account-level data and associated credit data for a nationally representative sample (5%) of mortgages active at any time since January 1998. The credit records start prior to the time the mortgage was first reported (but no earlier than 1998). The consumer reporting agency updates the account and credit data quarterly and adds a 5% sample of new mortgages to the database. The agency said records are de-identified and that the identities of creditors, servicers, or other furnishers of data to the consumer reporting agency are de-identified as well before the data is provided to the FHFA or the bureau. The NMDB includes approximately 12 million residential mortgages, the bureau said.
- Credit Card Database (CCDB): The CCDB is a sample of de-identified account-level (such as account balance) credit card data. The bureau said it does not contain transaction level data pertaining to consumer purchases. The agency said it has used the CCDB for market monitoring, including the preparation of a biennial report to Congress on the credit card marketand to “inform decisions about priorities for supervisory examinations and the scope of such examinations.” The agency said it has also used the CCDB for a number of working papers prepared by bureau researchers, as well as for research that has informed rulemakings and supervision.
- Home Mortgage Disclosure Act (HMDA): HMDA data is used to identify possible discriminatory lending patterns and to enforce anti-discrimination statutes like the Equal Credit Opportunity Act (ECOA). As part of supervising very large banks and nonbank mortgage lenders, the bureau said it reviews the accuracy of HMDA data and the adequacy of HMDA compliance programs. The agency also uses HMDA data for market monitoring and research purposes, including research to inform rule makings.
- Call Reports: Include Reports of Condition and Income from financial institutions in various financial markets. The data are collected by prudential regulators (by the FFIEC or the NCUA) and state regulators (through the Conference of State Bank Supervisors [CSBS]). The bureau said it uses these data in a variety of research and analysis contexts. For example, these data provide the authoritative basis for determining which depository institutions have assets over $10 billion and thus fall within the agency’s supervisory and enforcement jurisdiction. The agency likewise has used Call Report data to monitor the market for overdraft services and to report on the amount of overdraft fees paid by consumers and the fees’ contribution to bank earnings. The bureau also said it used Call Report data in combination with HMDA data (as well as Census data and data from its Consumer Credit Panel) to estimate the effect that alternative definitions of “small creditor” and “small servicer” would have in conjunction with several of the bureau’s mortgage rulemakings under title XIV of the Dodd-Frank Act.