Last week Peter Orszag, the Director of the Office of Management and Budget (OMB) issued a memo called the “Open Government Directive.” This memo calls for federal agencies to “proactively use modern technology to disseminate useful information, rather than waiting for specific requests under FOIA,” and specifically directed each agency to “identify and publish online in an open format at least three high-value data sets” within 45 days.
This is a pretty big deal. Not only are FOIA requests often slow and cumbersome, it can be difficult for the public to even know what to ask for if they don’t know what information an agency maintains in its files. If agencies post this information without being asked, the public will have a much easier time monitoring the activities of their government.
The public is encouraged to nominate datasets for release, and today we filed comments requesting the release of information regarding applications to the United States Department of Agriculture Rural Development Direct mortgage loan program. We are wrapping up a research project regarding this program (keep your eyes here for the report soon), but our research was hindered by a dearth of information about USDA’s mortgage lending. Most private lenders report more about their lending activities than does the USDA.
Given our research, we filed the following comments this afternoon:
Re: Open Government Directive:
The United States Department of Agriculture Rural Development (USDA RD) makes home mortgage loans directly to Low and Very Low income rural borrowers through the 502 Direct lending program. In 2008, USDA RD made 10,179 loans through this program.
USDA maintains a database of applicants to this program called UniFi. USDA’s Direct Single Family Housing Loans and Grants Field Office Handbook states: “UniFi is a web based application used for loan origination. It retains applicant information, makes complex computations, and maintains a central record of all activities associated with an individual application from the time of pre-qualification through loan closing.”
The UniFi data set meets the definition of a “high value” dataset under the Open Government Directive. This data can be used by the public to increase agency accountability and responsiveness as well as improve public knowledge of USDA RD and its operations. The Texas Low Income Housing Information Service nominates the Unifi data set for prompt release under the Open Government Directive.
Personally identifiable Information in UniFi should withheld by the department; however, loan-level information about borrower and loan characteristics can and should be provided to the public. Private lenders publicly report loan-level information under the Home Mortgage Disclosure Act (HMDA). USDA RD, as a public lender, should release information from UniFi that is at least equivalent to that required by HMDA, including:
- Sex, race, ethnicity and national origin of borrowers,
- Income category of borrower
- Principal balance of loan
- Geographical Region of property (e.g zip code or census tract)
- Loan purpose (e.g. purchase, construction, repair)
- Originating USDA office
- Date of application and date of action (to allow calculation of processing time)
- Reason for denial
- Effective Interest rate of loan, including amount of Interest Payment Subsidy
- Loan to Value Category
- Repayment period
USDA RD also maintains a linked dataset called “MortgageServ.” Complimentary information (such as delinquency status) in Mortgageserv should be released in conjunction with the UniFi data.
This information can and will be used by the community served by USDA Rural Development to monitor the success and equity of its direct lending program, and we urge the prompt release of this data.
Texas Low Income Housing Information Service
Those are our comments, but you can participate in this process as well. Let the OMB know what datasets you would like prioritized under the Open Government Directive at www.data.gov/suggestdataset.