Archive

Earlier this week, the CFPB Released the 2023 Modified HMDA loan/application registers (LARs). The HMDA modified LARs are now available for each institution that filed HMDA data collected in 2023. Institutions can find the data on the Federal Financial Institutions Examination Council’s (FFIEC) HMDA Platform for approximately 5,089 HMDA filers. The published data contains mortgage loan-level information for 2023 as modified to protect applicant and borrower privacy in accordance with the Consumer Financial Protection Bureau’s […]

The most common HMDA questions that we receive are about how to properly  report multipurpose and multifamily properties. And it’s understandable… The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome new requirements. Here’s a breakdown of how to properly report multifamily and multipurpose properties for HMDA Let’s start with ‘multifamily”. The construction method and total units, together, replaced property type reporting […]

HMDA Enforcement Actions in 2023… The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome requirements. These changes continue to prove to be cumbersome and taxing. Program failures continue to plague financial institutions and in 2023, there were three very large enforcement actions for failing to file accurate data. Additionally, due to a lawsuit the CFPB had to rescind the 100 loan […]

Yesterday, the CFPB released the 2024 HMDA Filing Instructions Guide (FIG). In case you haven’t used a FIG before, it is a technical resource designed to help HMDA covered financial institutions file annual HMDA data. The 2024 HMDA FIG is for filing data collected in 2024 and reported in 2025. The 2024 HMDA FIG, as well as other resources for HMDA filers can be found here. ______ If you’d like to take a closer look at […]

The federal bank regulatory agencies are announcing the Federal Financial Institutions Examination Council’s (FFIEC) revised “A Guide to HMDA Reporting: Getting It Right!” (2023 guide). The 2023 guide provides resources to help banks1 comply with the Home Mortgage Disclosure Act (HMDA) and Regulation C, its implementing regulation (12 CFR 1003). The 2023 guide reflects a technical amendment to the 2020 HMDA rule to adjust the loan volume thresholds effective January 1, 2023,2 for reporting HMDA data on […]