The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) are issuing designated key Home Mortgage Disclosure Act (HMDA) data fields to support the efficient and effective evaluation of financial institutions’ compliance with HMDA’s requirements.
Statement of Applicability to Institutions With Total Assets Under $1 Billion: This Financial Institution Letter applies to all FDIC-supervised institutions subject to HMDA and Regulation C. A HMDA exemption applies to institutions with assets at or below a threshold specified in Regulation C.
- Amendments to Regulation C effective January 1, 2018, (the HMDA Amendments) establish the data financial institutions will collect and report pursuant to HMDA requirements.
- The Federal Financial Institutions Examination Council (FFIEC) issued HMDA Examiner Transaction Testing Guidelines (the Guidelines) establishing procedures for examination staff to use when validating HMDA data.
- The Guidelines include a data sampling process that involves prioritizing designated data fields for review, or reviewing all data fields within a sample. However, the Guidelines themselves do not establish designated key data fields.
- To promote efficiency, coordination, and consistency, the FRB, the FDIC, and the OCC have jointly identified and Designated Key HMDA Data Fields, consistent with their traditional practice of designating key fields considered to be most important to ensuring the integrity of analyses of HMDA data.
- FDIC compliance examination staff will prioritize the Designated Key HMDA Data Fields in reviewing data that is collected by financial institutions in or after 2018 pursuant to the HMDA Amendments.