I just had a wild thought about privacy and the HMDA Data.

The HMDA Public LAR contains the following information: Type of loan, purpose of loan, Owner occupancy status, loan amount, action taken, Census Tract, County, State location, race and sex of the applicants/borrowers/ and income.

How difficult would it be for someone to obtain Public LAR's and cross check the information available from a County Recorder's office for Deeds of Trust that have been recorded? The Deed of Trust contains name of lender, name of borrower, address of the property, and amount of the loan.

How hard would it be to build a database containing name, address, income, race, and sex based upon these two PUBLICALLY available databases?

Who could want this information? Predatory lenders, marketers of ethnically targeted products, hate groups?

Does anyone else think that is a scary thought OR that it could already be happening?

If you are a homeowner, you probably have been receiving all sorts of marketing material regarding home equity loans and the like. Since the information is public, any sort of person can access it, for whatever reason.

And yes, it is scary!

Oh yes, I am very familiar with the TONS of junk mail I have received, but never with the thought that someone would be able to discover my race and income to go along with my address.

And only HMDA makes that possible!

I also don't believe that the general public realizes that this specific information is submitted to the federal government AND made available to the public....really anyone who asks!

Most people are familiar with the race/sex questionnaire, but probably not the extent that the information is reported and made available. Now - if you add in the expanded HMDA reporting proposals, I think you would open up a whole new market to predatory lenders. They could see the APR's and cherry pick potential victims for their scams based on income and race.

You are absolutely right. I'm sure the databases that could be created from both sources of information would be diverse enough to match the information. It would be more difficult in large market areas, but in the area I'm in, it would be a piece of cake.

Bonnie raises an interesting point. And here's an esoteric historical fact. When HMDA was no more than a spark in Congress' eye, the regulatory agencies raised the very concern that Bonnie raises. The government's approach then was to follow the Bureau of Census' guidelines for protecting the privacy of individuals. Now, however, the capabilities of those who wish to violate privacy are enormously enhanced. The question should now be very different. Consider these capabilities in your comments on the proposal to also collect loan terms. Your race and APR could become public knowledge!