The much anticipated Filing Instructions Guide (FIG) has been published by the Consumer Financial Protection Bureau (CFPB). Actually the CFPB has published two FIGs – one for data collected in 2017 and one for data collected in 2018 or later. The 2017 FIG is 47 pages in length. The 2018 Guide is 78 pages in length. Both are dated July 2016.
The CFPB has also published a Technology Review and Frequently Asked Questions documents, which provide details regarding the changes.
Data Collected in 2016, Submitted in 2017 – There are no changes to the data collected or to the submission process for Home Mortgage Disclosure Act (HMDA) data collected by financial institutions in 2016. Financial institutions will file HMDA data with the Federal Reserve Board (FRB) using the FRB’s instructions, file specifications, and edits familiar to HMDA users.
Data Collected in 2017, Submitted in 2018 – There are no changes in the data, but there is a new data submission process beginning with HMDA data collected by financial institutions in or after 2017. Financial institutions will file HMDA data with the (CFPB) using the HMDA Platform. The bank regulatory agencies have agreed that filing HMDA data collected in or after 2017 with the CFPB will be deemed submission to the appropriate Federal agency.
Data collected by financial institutions in or after 2017 will be filed online with the CFPB. The FFIEC Data Entry Software (DES) will continue to be used only for data collected in or before 2016. The CFPB is developing a loan/application register formatting tool that will be provided to help filers format certain data into a pipe delimited text file. This tool may be especially helpful for filers with small volumes of reported loans who do not use vendors or other software to prepare their HMDA data for submission.
Beginning with the data collected in 2017, financial institutions will no longer be able to submit HMDA data without correcting or validating all edits. All syntactical and validity edits must be corrected and quality and macro quality edits must be corrected or validated before a filer can submit HMDA data to the CFPB.
Data Collected in 2018, Submitted in 2019 – The data collected changes in a significant way. The new data submission process that begins with the 2017 data continues.
All of the information mentioned above is available at Resources for HMDA Filers https://www.consumerfinance.gov/data-research/hmda/for-filers.
