Mortgage Insurance Loan Activity Report (MILAR)

The Mortgage Insurance Loan Activity Report, commonly abbreviated as MILAR, is the primary datacollection tool used by the Federal Housing Finance Agency (FHFA) and the Department of Housing and Urban Development (HUD) to monitor the performance of federallyinsured mortgage loans. The report provides a detailed snapshot of loan origination, underwriting, and servicing activity for each loanoriginating institution that sells or services loans backed by the Federal Housing Administration (FHA), the Veterans Affairs (VA), the United States Department of Agriculture (USDA), or other Federal mortgage insurance programs.

Why MILAR Matters

Accurate and timely MILAR filing is essential for several reasons:

• Regulatory oversight: The FHFA uses MILAR data to assess the health of the mortgage market, identify emerging risk trends, and enforce compliance with program rules.
• Policy development: Policymakers rely on MILAR trends to shape loanlimit adjustments, creditscore thresholds, and other program parameters.
• Investor confidence: Lenders and investors review MILAR statistics when evaluating the credit quality of mortgageinsurance pools.
• Consumer protection: Transparency in loan characteristics helps protect borrowers from predatory practices.

Who Must File?

Any entity that originates, purchases, or services a loan that is insured or guaranteed by a Federal agency must submit a MILAR filing for each reporting period. This includes:

1. Bank holding companies and their subsidiaries.
2. Mortgage bankers and mortgage brokers.
3. Credit unions that originate FHA, VA, or USDA loans.
4. Nonbank lenders that sell loans to the secondary market.

Failure to file, or filing incomplete or inaccurate data, can result in civil penalties, increased supervisory scrutiny, or loss of eligibility to participate in Federal mortgageinsurance programs.

Reporting Frequency & Deadlines

MILAR is a quarterly report. The standard filing schedule is as follows:

Quarter	Data Collection Period	Filing Deadline
Q1	January1March31	May15
Q2	April1June30	August15
Q3	July1September30	November15
Q4	October1December31	February15 (following year)

All data must be submitted electronically through the FHFAs eReporting Portal. Late filings are subject to a $5,000 perday penalty, with a maximum of $250,000 per quarter.

Key Data Elements Required

The MILAR filing consists of three main sections:

1. Loan Origination Summary

• Loantype breakdown (FHA, VA, USDA, etc.)
• Loan purpose (purchase, refinance, home improvement)
• Geographic distribution by state and ZIP code
• Borrower creditscore ranges
• Debttoincome (DTI) ratios
• Loantovalue (LTV) ratios

2. Underwriting & Eligibility

• Verification of income, assets, and employment
• Documentation of appraisal values and property types
• Compliance with programspecific eligibility criteria (e.g., veteran status for VA loans)

3. Servicing Activity

• Delinquency status by 30, 60, 90day buckets
• Foreclosure initiation and completion rates
• Loss mitigation actions (loan modifications, repayment plans, etc.)
• Chargeoff and default amounts

Each lineitem must be accompanied by a unique loan identifier (usually the loans ULN or FICO reference) to enable traceability.

How to Submit MILAR

1. Gather source data: Export loanlevel information from your loanorigination system (LOS) and servicing platform. Most vendors provide a MILARcompatible CSV template.
2. Validate the file: Use the FHFA validation tool to check for missing fields, formatting errors, and outofrange values.
3. Upload: Log into the eReporting Portal, select the appropriate quarter, and upload the validated file.
4. Confirm receipt: The system generates a receipt number and a summary of any warnings that must be addressed before final acceptance.
5. Maintain records: Retain the original data files and validation reports for at least five years in case of an audit.

Common Filing Errors and How to Avoid Them

• Incorrect date format: Use YYYYMMDD; the system rejects MM/DD/YYYY.
• Missing loantype codes: Each loan must be tagged with the correct program code (e.g., FHA203(b)).
• Inconsistent LTV calculations: Ensure the appraisal value used matches the one reported to the insurer.
• Duplicate loan identifiers: A unique ULN must appear only once per reporting period.
• Failure to report zerobalance loans: Even loans that have been fully paid off must be reported with a zero balance flag.

Benefits of Accurate MILAR Reporting

Beyond regulatory compliance, accurate reporting offers tangible advantages:

• Enhanced risk management: Detailed delinquency data helps lenders allocate capital more efficiently.
• Better pricing models: Access to granular loancharacteristics enables more precise creditrisk pricing.
• Improved stakeholder confidence: Investors and rating agencies view transparent reporting as a sign of strong governance.
• Eligibility for incentives: Some programs provide fee reductions for lenders that maintain low default rates as demonstrated in MILAR data.

Impact on Borrowers

When lenders submit highquality MILAR data, borrowers indirectly benefit through:

• More stable loanpricing environments.
• Quicker approval processes, as lenders can demonstrate compliance with underwriting standards.
• Greater access to lossmitigation programs, since accurate delinquency tracking enables timely assistance.

Future Trends in MILAR Reporting

The FHFA is actively modernizing the MILAR framework. Anticipated changes include:

1. Realtime data feeds: APIbased submissions that allow daily updates rather than quarterly snapshots.
2. Expanded data fields: Inclusion of borrower ethnicity and gender data to support fairlending analytics.
3. Machinelearning validation: Automated anomaly detection to flag outliers before submission.
4. Integration with blockchain: Pilot projects exploring immutable loanlevel records for auditability.

Frequently Asked Questions

Q: What happens if I discover an error after filing?

A: Submit a corrected file through the Amendment function on the portal within 30 days of the original filing. The FHFA will replace the previous data in its database.

Q: Can a loan be reported in multiple quarters?

A: No. Each loan should appear only once for the quarter in which it was originated or serviced. Subsequent activity (e.g., delinquency status) is reported in the servicing section of later quarters.

Q: Are there exemptions for small lenders?

A: Lenders with fewer than 25 insured loans in a quarter may request a simplified filing, but they must still meet the core dataelement requirements.

Q: How does MILAR differ from HMDA?

A: The Home Mortgage Disclosure Act (HMDA) focuses on demographic and geographic data for all home loans, while MILAR is specific to federally insured loans and includes detailed underwriting and performance metrics.

Helpful Resources

• FHFA MILAR Guidance Official instruction manual and sample files.
• CFPB Mortgage FAQs General information on mortgage insurance programs.
• NMLS Consumer Access Verify lender licensing and registration.
• U.S. Department of Housing and Urban Development (HUD) Program eligibility criteria and updates.

Staying current with MILAR requirements helps lenders maintain good standing with regulators, protects borrowers, and contributes to a healthier national housing finance system.