The FFIEC has finally released an updated HMDA Getting It Right Guide.
The FFIEC release the new guide yesterday, which is the first revision of the guide since 2013. The new version has been completely revised to reflect the HMDA changes from the 2015 final rule as well as the 2017 amendments that went into effect on January 1, 2018.
While the Getting It Right Guide has long been the ultimate resource for HMDA filers, the new 2018 version does not appear to provide any new substantial content. Rather, the guide is merely a collection of previously released CFPB guidance and resource documents, though the Guide does now compile all of these tools into one place.
The main part of the guide covers 34 pages and provides a very generalized overview of the current HMDA requirements. The remainder of the 327 page document is just a compilation of existing CFPG guidance and resources such as:
- The CFPB HMDA Small Entity Compliance Guide
- The CFPB Instructions on Collection of Data on Ethnicity, Race, and Sex
- The CFPB Transactional Coverage Chart
- The CFPB Institutional Coverage Chart
- Regulation C
- The Official Interpretations to Regulation C
- The new HMDA Poster
The fact that there is no new guidance in this guide leaves me with mixed feelings. First, it is a somewhat of a relief to not have yet another document that must be utilized in an already overwhelming mirid of guidance. It is also nice to have much of the guidance that a HMDA reporter needs all in one place. That said, this document also leaves me slightly disappointed as there are still numerous parts of the new HMDA rules that could really use additional clarification for HMDA reporters.
As a final thought, it will be interesting to see how quickly this guide is updated each time the CFPB makes a change to one of their resources, which will effectively leave the HMDA Getting It Right Guide out-of-date until a new revision is released.