HMDA & CRA 2018:  Are you on track?

HMDA and CRA Data

Jun. 22, 2018 – 

Managing the recent changes in the HMDA regulation is challenging. Luckily there are several online resources available to help guide you through the complexities of HMDA regulatory change. 

HMDA, CRA and Fair Lending data are heavily relied upon by regulators in Fair Lending and CRA exams, for branch expansion and M&A applications. This data is also used, at times, to cast light on an institution’s lending patterns. Institutions must ensure this data is accurate, reliable and complete or else be subject to heavy penalties, elongated or delayed examinations, potentially derailed expansion plans as well as negative public perception.

This past March 31st, depository institutions and non-depository institutions that originated more than 25 closed-end mortgage loans or more than 500 open-end lines of credit in each of the past two calendar years were required by the Consumer Financial Protection Bureau to change the HMDA data that is collected and the method the data is reported. 

"For decades, most sophisticated financial institutions had developed and implemented HMDA compliance methods, many times with the aid of third-party vendors. But the 796-page CFPB HMDA final rule includes sweeping changes regarding what is a covered institution, what new data will need to be collected, the process for reporting and disclosing the data, and how HMDA systems will be modified."

-Banking and Financial Services Policy Report

These changes are significant. The number of data fields that must be collected and reported increased to 110 (from 20.) The additional data is meant to provide additional information relating to the loan applicants, pricing and the underwriting process as well as information about the subject property that secures the loan and other new unique identifiers, such as the entity originating the loan. 

For a comprehensive list of the new HMDA data reporting requirements visit the CFPB’s online HMDA data reference chart.

Additionally, this new data is no longer submitted to the Federal Reserve Bank. It is now submitted directly to the CFPB through their online web-based portal. To achieve efficiencies, the CFPB no longer allows data submission to be a back and forth process.

The CFPB is using the 2018 data collection period as an opportunity to “identify gaps in the implementation” of HMDA and “make improvements in the HMDA compliance management system”. This means lenders across the United States that are still updating their HMDA Compliance Management Systems must have ironed out any data collection or reporting issues before 2018 data is reported in March 2019. In effect, this year was a dry run. Next year counts.

Regulatory change is hard. Are my folks trained? What loans are covered? Is our Loan Origination System (LOS) ready? Is our data complete and accurate? If you have questions such as these it may be time to get help. Wolters Kluwer has created a significant amount of extremely helpful content that is targeted to help you through the HMDA transition. Check out the Wolters Kluwer’s HMDA Resource Center. Or watch one of their 4 free webinars that are packed full of educational content and useful tips. You can find the webinars at these links:

If you are attending next week’s ABA Regulatory Compliance Conference don’t miss Industry Insights and Compliance Strategies for CRA, Fair Lending and HMDA This power breakfast event is sponsored by Wolters Kluwer and features experts in HMDA and CRA compliance topics. The session is scheduled for 7:30 A.M. to 8:30 A.M. on Monday June 25. If you need more help, we suggest reaching out to Wolters Kluwer.  They provide professional advisory services and technologies, such as HMDA Wiz and CRA Wiz that can help you comply with regulatory change. For more information, visit www.wolterskluwerfs.com/hmda.