All in HMDA

On March 29, 2019, the Consumer Financial Protection Bureau (CFPB) released the Home Mortgage Disclosure Act (HMDA) Modified Loan Application Registers (LARs).  This data was published for about 5,400 financial institutions and is the first year in which the “expanded data fields” - required by the 2015 HMDA rule - are available for public viewing, though some data has been modified for public viewing for privacy purposes.

The modified LAR data is required by statute to be available by March 31 of each year.  Prior to the implementation of the 2015 HMDA rule, financial institutions had to make their Modified LARs available to members of the public who requested them.  The 2015 rule, which became effective on 1/1/2018, eliminated this requirement.

On March 25, 2019, the CFPB announced the availability of the FFIEC 2019 HMDA Getting it Right (GIR) Guide.  Updated each year, the GIR guide is a valuable resource for assisting all institutions in their HMDA reporting. It includes a summary of responsibilities and requirements, directions for assembling the necessary tools, and instructions for reporting HMDA data.

The full GIR guide can be found at…

The 2019 edition is effective January 1, 2019, and applies to 2019 HMDA data that must be submitted by March 1, 2020.  This updated edition reflects amendments made to HMDA by the Economic Growth, Regulatory Relief, and Consumer Protection Act and the 2018 HMDA interpretive and procedural rule issued by the Consumer Financial Protection Bureau.

On March 7, 2019, the Office of the Comptroller of the Currency (OCC) released a bulletin (2019-12) explaining the key HMDA data fields for full and partial HMDA reporters.  In their bulletin, the OCC explains that key data fields have been identified to support the efficient and effective evaluation of banks’ compliance with HMDA requirements. Of the 110 total data fields, 37 have been identified as key fields by the OCC, Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) on an interagency basis. The OCC explains that OCC examiners will typically test and validate these 37 key fields for the banks that are required to collect, record, and report information for all HMDA data fields. For banks that qualify for a partial exemption from the HMDA data collection, recording, and reporting requirements, OCC examiners will typically test and validate 21 of those 37 fields.

While the revised HMDA rules have been in place for just over a year now, we are finding that a number of financial institutions are still struggling with a few of the quirks of the new rules.  Specifically, one question we have seen a few times in recent months is this: Is a spec home HMDA reportable? To fully understand the answer to this question, we need to first discuss how the changes to the 2018 HMDA rules relate to this topic.  You see, under the old HMDA rules, spec homes were…

HMDA Exemption Property Address

In this Compliance Clip (video), Adam discusses how the Property Address data point applies to the partial exemption. Specifically, he provides guidance on how exempt institutions are to report the street, city and state when they are listing the state data field as part of the Property Location data point. As you would expect, this is a fairly complex topic that has caused quite a bit of confusion, so Adam attempts to break the rules down into easy-to-understand layman’s terms.

If you are an exempt reporter or plan to use the partial exemption for your 2019 data, be sure to check out our Compliance Class (video webinar) on the HMDA partial exemption in our store. Everything you need to know about the partial exemption is covered in less than an hour and includes a comprehensive training manual for reference and a Q&A of some more complex questions relating to the partial exemption. View the Compliance Class (video webinar) at

HMDA Exemption for Large CRA Reporters

Adam uses this Compliance Clip (video) to talk about one of the nuances of the CFPB’s Interpretive and Procedural Rule regarding the HMDA partial exemption. Specifically, this video explains how the property address and property location data points apply to large CRA reporters who also qualify for the HMDA partial exemption. The answer might not be exactly what you think…. or even what the CFPB intended.

On December 31, 2018, the CFPB adjusted the HMDA exemption threshold from $45 million to $46 million.  The adjustment is based on the 2.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2018. Therefore, banks, savings associations, and credit unions with assets of $46 million or less as of Dec. 31, 2018, are exempt from collecting data in 2019.