Archive

HMDA GETTING IT RIGHT IS BACK

The Federal Financial Institutions Examination Council (FFIEC) has released an updated and expanded version of the publication A Guide to HMDA Reporting – Getting it Right (aka the HMDA bible). The publication had not been updated since 2013. The 327-page 2018 Guide is updated for the revisions to the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the Home Mortgage Disclosure Act (HMDA) that were effective January 1, 2018. The Guide includes the  revised […]

CFPB LAUNCHES ADDITIONAL HMDA TOOLS

On December 27, 2017 the Consumer Financial Protection Bureau(CFPB) launched its HMDA Check Digit Tool and Rate Spread Calculator. These tools, or similar tools, are needed to assure compliance with new HMDA data collection rules that are effective on January 1.2018. HMDA Check Digit Tool – The Check Digit Tool: Generates a two character check digit when you enter a Legal Entity Identifier (LEI) and loan or application ID; and Validates that a check digit […]

CFPB ANNOUNCES HMDA FORBEARANCE

On December 21, 2017 the Consumer Financial Protection Bureau (CFPB) issued a public statement announcing that the CFPB: Does not intend to require data resubmission unless data errors are material or assess penalties with respect to errors for data collected in 2018 and reported in 2019 under the Home Mortgage Disclosure Act (HMDA). Intends to open a rulemaking to reconsider various aspects of the CFPB’s 2015 HMDA rule, such as the institutional and transactional coverage […]

INTERAGENCY HMDA KEY FIELDS PUBLISHED

The FRB, the FDIC, and the OCC recently issued Designated Key HMDA Data Fields to support the efficient and effective evaluation of financial institutions’ compliance with the HMDA’s requirements. Of 110 data fields, 37 are identified as key fields. In certain circumstances, however, examiners may determine it necessary to review additional HMDA data fields, as appropriate. Background The HMDA, which is implemented by Regulation C (12 CFR 1003), requires certain financial institutions to collect, record, […]

URLA IMPLEMENTATION TIMELINE

On September 26, 2017 Fannie Mae and Freddie Mac (the GSEs) published guidance on the implementation timeline for the redesigned Uniform Residential Loan Application (URLA). Demographic Information Addendum The Consumer Financial Protection Bureau (CFPB) has finalized their Technical Corrections and Clarifying Amendments to the Home Mortgage Disclosure Act (HMDA) Regulation C. The GSEs have updated the Demographic Information Addendum based on this final rule. The changes were made only to the form instructions and not […]