Compliance: HMDA data due to CFPB by March 2

February 5, 2020

NCUA’s latest Letter to Credit Unions (20-03) outlines submission of 2019 Home Mortgage Disclosure Act (HMDA) data. Credit unions located in metropolitan areas that engage in certain types and volume of residential mortgage lending, and that had assets exceeding $46 million as of Dec. 31, 2018, must file a report this year on mortgage loan applications received during 2019.

Credit unions subject to HMDA requirements in calendar year 2019 must submit loan/application register data to the Consumer Financial Protection Bureau (CFPB) by March 2.

Credit unions must submit their HMDA data using the HMDA Platform. No other submission methods are permitted. Credit unions will use the Federal Financial Institutions Council’s (FFIEC) HMDA Platform upload their loan/application register data, review edits, certify the accuracy and completeness of the data and submit data for the filing year.

Credit unions must submit data collected in a pipe delimited text file (.txt). A loan/application register (LAR) formatting tool has been developed to help format certain data into a pipe delimited text file.

The LAR Formatting Tool may be especially helpful for credit unions with small volumes of reported loans that do not use vendor or other software to prepare their HMDA data for submission.

Credit unions must address all edits prior to submitting their HMDA data. The edit report will be web-based:

  • Edit reports will not be e-mailed to credit unions in PDF format. Instead, the CFPB edit reports will be viewed and can be downloaded from the HMDA Platform.
  • Responses to the edits will not be faxed or e-mailed to the CFPB. The HMDA Platform will guide credit unions through the process of addressing edits.

As part of the submission process, an authorized representative of the credit union with knowledge of the data submitted shall certify to the accuracy and completeness of the data submitted.

Additional resources, including the Filing Instructions Guide for HMDA data collected in 2019, can be found on the Resources for HMDA filers page on the CFPB’s website.