CFPB Extends the 500 open-end lines of credit threshold to January 1, 2022

On October 10, 2019, the CFPB announced that it issued a final rule extending the current temporary threshold of 500 open-end lines of credit for open-end institutional and transactional coverage. For data collection years 2020 and 2021, financial institutions that originated fewer than 500 open-end lines of credit in either of the two preceding calendar years will not need to … Read More

CFPB Beta Launch of HMDA Platform

From the CFPB – The Bureau is pleased to announce the beta launch of the new HMDA Platform. The main objective of the beta release is to provide financial institutions an opportunity to become familiar with the HMDA Platform and, in particular, determine whether their sample LAR data complies with the reporting requirements outlined in the Filing Instructions Guide for … Read More

CFPB HMDA Implementation Materials

The CFPB has updated their cart Collection and Reporting of HMDA Information about Ethnicity and Race.  Additionally, the CFPB has published a new chart, Reportable HMDA Data: A Regulatory and Reporting Overview Reference (“Reporting Reference Chart”) intended to be used as a reference for data points required to be collected, recorded, and reported under Regulation C. The Reporting Reference Chart … Read More

FDIC Releases Interagency Designated Key HMDA Data Fields List

From FIL-51-2017: Summary: 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 … Read More

HMDA Examiner Testing Guidelines

The FFIEC released its HMDA Examiner Transaction Testing Guidelines for institutions that report HMDA data.  The Guidelines will apply to examination of HMDA data collected beginning in 2018 and reported beginning in 2019. From the CFPB: The Guidelines will help ensure accurate data and address reporting burden concerns When examining financial institutions, federal supervisory agencies with HMDA supervisory authority may … Read More

Proposed Amendments to Regulation C – HMDA

On April 13, the CFPB issued proposed amendments to the HMDA (Regulation C) Rule.  The CFPB describes the changes as being non-substantive in nature, and notes that the proposal is meant to provide “clarifications, technical corrections, or minor changes.” Included in the proposal are revised definitions along with related commentary: Automated Underwriting System:  The proposal would clarify that a system … Read More

Proposed changes to Regulation B to match Regulation C

The CFPB has issued a proposal to provide flexibility for lenders around the collection of applicants’ demographic data under the Home Mortgage Disclosure Act (Regulation C) and the Equal Credit Opportunity Act (Regulation B). Currently, under Reg B, creditors are prohibited from requesting information about consumers’ race or ethnicity, except to the extent required to monitor compliance with ECOA or … Read More

HMDA Technology Review

The CFPB published updated HMDA resource information including Technology Preview, Filing Instructions Guide for 2018 Data Collection and FAQs.  It is reprinted below for convenience – Introduction For HMDA data collected in or after 2017, a web-based data submission and edit-check system (the HMDA Platform) is being created to process Home Mortgage Disclosure Act (HMDA) data. It is expected that … Read More

2017 HMDA Data Submission Changes

The CFPB has posted information on changes to the submission process listed in the Filing Instructions Guide for HMDA data collected in 2017. Beginning with the HMDA data collected in 2017, filers will submit their HMDA data to the CFPB using a web interface referred to as the HMDA Platform. HMDA filers will interact directly with the HMDA Platform to file their HMDA data. … Read More

HMDA File Specifications

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. _  _  _ As a reminder, The NCUA released a Regulatory Alert reminding credit unions of … Read More