All in HMDA

In August, September, October, and November of 2020, the CFPB updated their Filing instructions guide for HMDA data collected in 2021. Updates to this guide are made annually, and there have been several different updates and versions to the FIG so far. HMDA filers will need to be sure to monitor the 2021 FIG to ensure they are using the current version of the guide.

On 10/15/2020, the CFPB released a new HMDA reference chart titled “Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2021.” In the chart, the CFPB explains that the chart is intended to be used as a reference for data points that must be collected, recorded, and reported under HMDA rules. The chart includes applicable regulation and commentary sections as well as parts of the Filing Instruction Guide. In addition, the chart helps to explain when to report not applicable or exempt, including the codes used for reporting not applicable or exempt.

On July 28, 2020, the CFPB released two new FAQs relating to the Home Mortgage disclosure Act (HMDA). This update is the second update to the CFPB’s HMDA FAQs in 2020, and those institutions still subject to HMDA reporting should review these new FAQs for compliance in your organization.

On 4/16/17, the CFPB released the long-awaited final rule which changes the threshold of mortgage originations for both closed-end and open-end credit, which determines whether or not a financial institution is a HMDA reporter. The good news is that some HMDA reporters will no longer need to collect and report HMDA data, starting on July 1, 2020. Click here to see a summary of the changes…

On March 6, 2020, the CFPB issued a new HMDA FAQ to clarify how to report when a natural person applicant submits a mail, internet, or telephone application under Regulation C, but does not provide race, ethnicity, or sex information. Specifically, question 7 under the “Ethnicity, Race, and Sex” section of the FAQs has been updated to provide additional guidance.

The Federal Financial Institutions Examination Council (FFIEC) has issued the 2020 edition of A Guide to HMDA Reporting Getting It Right! for Home Mortgage Disclosure Act-related data collected in 2020 and reported in March of 2021. The 2020 edition reflects updates to incorporate content from the HMDA Rule issued by the Consumer Financial Protection Bureau in October 2019. This compliance resource can help financial institutions better understand HMDA requirements, including the data collection and reporting provisions.

On January 23 of 2020, the CFPB released their latest version (v.4) of their HMDA Small Entity Compliance Guide. The updates in this version of the guide were made to align the guide with the October 10, 2019 final rule which implements the partial exemption for small filers.