Earlier this month, the CFPB released a few different resources for HMDA filers. These resources include the availability of the 2017 HMDA Data as well as the availability of the File Format Verification Tool. Guidance for small HMDA filers, however, has not yet been released though the CFPB has given a timeframe of by the "end of summer."
Availability of 2017 HMDA Data
On August 7, 2018, the Bureau announced the availability of the 2017 HMDA data which includes a few things. First, the “2017 HMDA Dynamic National Loan-Level Dataset” is now available, though the CFPB explained that this dataset it updated weekly to include late submissions and resubmissions. In this release, the CFPB explained that the Loan Application Register (LAR) and Transmittal Sheet (TS) records are available separately. Secondly, the National Aggregate report is now available which summarizes lending nationwide. In addition, the Aggregate and Disclosure reports are also both available, summarizing lending by both MSA/MD and by institution.
While in prior years HMDA reporters were required to place a copy of their HMDA data in their CRA public file, the new rules (starting in 2018) do not require this. In lieu of placing the data in the CRA public file, HMDA filers are now required to post a new version of the lobby notice which explains how the information can be obtained online from the CFPB.
In addition to the lobby notice, the CRA public file for each HMDA filer must contain a notice of the availability of the HMDA data. This notice is a separate requirement from the lobby notice, though it contains very similar language. The notice requirements are found in 228.43(b)(2) of Regulation BB (the Fed’s Version of CRA rules) as follows:
“(2) Banks required to report Home Mortgage Disclosure Act (HMDA) data. A bank required to report home mortgage loan data pursuant part 1003 of this title shall include in its public file a written notice that the institution’s HMDA Disclosure Statement may be obtained on the Consumer Financial Protection Bureau’s (Bureau’s) website at www.consumerfinance.gov/hmda. In addition, a bank that elected to have the Board consider the mortgage lending of an affiliate shall include in its public file the name of the affiliate and a written notice that the affiliate’s HMDA Disclosure Statement may be obtained at the Bureau’s website. The bank shall place the written notice(s) in the public file within three business days after receiving notification from the Federal Financial Institutions Examination Council of the availability of the disclosure statement(s).”
It is important to note that this notice is required to be placed in the public file within three business days after receiving notification about the availability of the disclosure. This means that the notice should already be in the CRA public file for HMDA filers.
The File Format Verification Tool
The CFPB also announced the availability of the File Format Verification Tool. This tool - which essentially runs on the same software as the HMDA Platform - will be used for HMDA data collected in 2018 and submitted in 2019 as a resource for testing whether a financial institution’s HMDA file meets certain formatting requirements specified in the HMDA FIG (Filing Instructions Guide). Basically, if a data file passes all checks on the FFVT website, the file will be considered to be in the correct format required to be uploaded to the HMDA Platform.
In addition, the CFPB explained in their release that the FFVT “was developed as an anonymous resource without a log-in function. This means that, while the file can be used to test formatting, the information is not saved. The benefit in this requirement to re-upload HMDA the HMDA LAR each time a financial institution wants to test their accuracy is that the information also won’t be provided to any Federal agency.
In order to use the FFVT, HMDA files must meet certain formatting requirements, as explained in the FIG. For example, files must:
Be in a pipe-delimited format;
Have the proper number of data fields; and
Format data fields as integers, where applicable.
The instructions for the FFVT explain that the program will run more slowly for larger filers, such as those with more than 20,000 entries. Therefore, smaller community banks and credit unions generally shouldn’t experience lag times using the drag and drop program.
Links to HMDA Resources
The HMDA Data can be found here.
The dynamic loan-level dataset can be found here.
The 2018 File Format Verification Tool can be found here.
