Polygon Research’s Insights on Mortgage Loan Costs: Response to CFPB’s RFI on Fees
On August 2, 2024, Polygon Research submitted our response to the CFPB's Request for Information (RFI) regarding fees imposed in residential mortgage transactions. As experts in unlocking mortgage data through HMDAVision®, we used our unique insights into HMDA LAR data to address some significant gaps in understanding loan costs.
Our Main Points
Data Gaps Matter
Current HMDA data doesn’t include key details like the application date or rate lock, which are crucial to understanding why borrowers pay certain fees. We’re advocating for more granular data fields, like separating borrower-paid and seller-paid discount points and expanding fee disclosures from the closing disclosure forms.
Fee Volatility
Loan costs are driven by multiple factors, including discount points, lender credits, and market conditions. In our analysis, loan costs jumped 22.85% from 2021 to 2022 and another 10.68% from 2022 to 2023, driven largely by interest rate changes.
More Data, Better Decisions
We encourage the CFPB to release more detailed HMDA data. This would empower all stakeholders—from lenders to borrowers—with a clearer picture of the fees they’re paying and why.
Polygon Research is pushing for a more transparent mortgage market where both lenders and borrowers have access to better data. Read our full response to learn more about how we’re driving transparency in mortgage lending: Regulations.gov
