The CFPB has posted HMDA file specifications for 2017 and 2018.
For data collected in 2016, credit unions should follow the FFIEC’s file specifications.
For data collected in 2017 and data collected in or after 2018, credit unions should follow the CFPB’s file specifications.
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As a reminder, The NCUA released a Regulatory Alert reminding credit unions of the requirement to collect and report HMDA data during 2016.
The credit union must collect HMDA data during 2016 if:
- Your credit union’s total assets as of December 31, 2015, exceed $44 million;
- Your credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2015; and,
- During 2015, your credit union originated at least on home purchase loan (other than temporary financing such as a construction loan) or refinanced a home purchase loan, secured by a first lien on a one-to-four-family dwelling.
If your credit union meets all three criteria, you must collect HMDA data during calendar year 2016 and submit the data to the Federal Reserve Board no later than March 1, 2017.
https://www.ncua.gov/Legal/Documents/Regulatory%20Alerts/RA2016-01.pdf
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And, remember that data reporting requirements will change for 2017 and 2018:
On October 13, 2015, the CFPB amended Regulation C expanding the reporting requirements. Included in the changes were the definitions of covered institutions and covered transactions, changes to public requests, submission of reports, along with new and modified data fields – for a total of 48 fields.
The CFPB released its Compliance Guide that includes the key changes and effective dates of the new requirements, institutional and transactional coverage, and the reportable data, for Regulation C.
Along with the Guide, the CFPB also released an overview of the changes to the HMDA rule issued October 15, 2015, a reference on when to report data as not applicable, and a reference for HMDA data required to be collected, recorded and reported. The release also includes coverage charts for 2017 and 2018 to help determine whether the credit union is required to abide by the new requirements.
