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Home » Compliance: FFIEC posts HMDA guide, CFPB publishes LARs
Policy & Issues

Compliance: FFIEC posts HMDA guide, CFPB publishes LARs

April 1, 2019

The Federal Financial Institutions Examination Council (FFIEC) and the Consumer Financial Protection Bureau (CFPB) issued resources for Home Mortgage Disclosure Act (HMDA) compliance last week.

The FFIEC’s guide covers HMDA data collected in 2019 for submissions due March 1, 2020, while the CFPB published HMDA Modified Loan Application registers for appriximately 5,400 financial institutions.

A Guide to HMDA Reporting: Getting it Right! provides credit unions with information about HMDA reporting, including a summary of responsibilities and requirements, directions for assembling the necessary tools and instructions for reporting HMDA data.

New in the 2019 guide are:

  • Appendix F, which is a partial exemptions chart illustrating the 26 data points covered by HMDA partial exemptions created by the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155). It also contains the 22 data points not covered by the partial exemptions; and
  • Appendix G, which is a data fields and data points chart listing data points, corresponding data fields and data field numbers. It also indicates the data points covered by HMDA partial exemptions.

Credit unions can also find more information about HMDA on NCUA’s Consumer Compliance Regulatory Resource homepage.

The CFPB’s publishing of LARs contain the first year in which additional data reported by certain institutions under the 2015 HMDA rule will be available. The modified LARs contain loan level information for 2018 in individual HMDA filers, modified to protect privacy.

According to the CFPB, additional information will be published later this year related to HMDA, including a complete loan level dataset and HMDA aggregate and disclosure reports.

These will be accompanied by a Data Point article highlighting key trends. The information to be released this year will include certain new data points, which can provide more insights into the mortgage lending practices of institutions.

The CFPB anticipates applying particular rigor and analysis to address data anomalies, including in the new data points and describing the context in which the data may be best understood

In addition to the CompBlog, CUNA’s Compliance Community contains discussion boards and a number of other resources for credit union compliance professionals around the country.

KEYWORDS compliance HMDA
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