On October 23, 2018, the CFPB released the Filing Instruction Guide (FIG) for data collected in 2019. This guide comes less than two months after the most recent version of the guide (August 2018), but is designed to be used for data collected during 2019. The FIG is considered to be a “technical resource to help financial institutions file HMDA data collected in 2019 and reported in 2020.”
Overall, the changes to the 2019 FIG are not significant, though there are four changes worth noting. First, the 2019 FIG added several options (items 18-24) for AUS result values. This information will be important for HMDA reporters that utilize automated underwriting systems. Secondly, the description for the debt-to-income ratio acknowledges that the DTI could be a negative number. Third, the interest rate data point was modified to accept an interest rate of “0”. This will be important for HMDA filers that originate interest free loans. Finally, the 2019 FIG added edit Q646 that will now produce a validation request whenever an institution utilizes the partial exemption.
The October 2018 FIG (used for 2019 data) lists nine changes from the prior version. These changes include the following:
Section 2.1 and Section 2.2
Updated to indicate no change in required data submission process from the August 2018 FIG to the 2019 FIG.
Section 3.4, Table 1 and Section 4.2.1
Updated Description of Federal Agency. Changed “Consumer Financial Protection Bureau (CFPB)” to “Bureau of Consumer Financial Protection (Bureau).”
Section 3.4, Table 1 and Section 4.2.2
Updated examples for Application date and Action Taken Date.
Changed the application date from “20180721” to “20190721.”
Updated Description of Credit Score values.
Added and updated AUS Result values including the following:
20. Accept/Unable to Determine
21. Refer with Caution/Eligible
22. Refer with Caution/Ineligible
23. Refer/Unable to Determine
24. Refer with Caution/Unable to Determine
Updated instructions on reporting DTI to accept negative number.
“The HMDA Platform can accept up to 15 decimal places and can accept negative numbers for Debt-to-Income Ratio.”
Updated instructions for reporting Credit Score.
“c. Use Code 7777 if your institution relied on a credit score that is not a number (e.g., a credit score of “Meets Threshold”). Code 7777 should not be used if a credit scoring model that produces numeric credit scores returns a result stating that the credit score could not be determined.”
Updated instructions for reporting AUS results.
The instructions add new options 18 through 24 as mentioned previously.
Section 5.2, Table 1
Updated table to show 2019 edit revisions.
V677 - Interest Rate data point was modified to allow a response of 0
Q632 - AUS data point edit was modified to revise expected AUS results to include codes 8, 13, 16, 18, and 19.
Q633 - AUS data point edit was modified to revise expected AUS results to include codes 3, 4, 5, 8, 10, 13, 14, 15, 16, 18 or 19.
Q643 - AUS data point edit was modified to revise expected AUS results to include codes 1, 2, 3, 4, 5, 6, 7, 15, or 16.
Q644 - AUS data point edit was modified to revise expected AUS results to include codes 8, 9, 10, 11, 12, 13, or 16.
Q645 - Loan Amount data point had a new edit added to check for unexpectedly low loan amounts.
Q646 - All data points eligible for the partial exemption received a new edit to verify that a financial institution is eligible to take partial exemptions.
Q647 - Federal agency data point has a new edit to verify that a financial institution is eligible to take partial exemptions.
Section 5.3, Table 6
Revised edit V677.
The edit added “or equal to” to the statement of “Interest Rate must be a number greater than or equal to 0…”
Section 5.3, Table 7
Revised edits Q632, Q633, Q643, and Q644 related to automated underwriting systems.
Added edit Q645 for loan amounts, adding the following two options:
1) Loan Amount should generally be greater than or equal to $500 (reported 500).
2) If Loan Purpose equals 1, then Loan Amount should generally be greater than or equal to $1,000 (reported 1000).
Section 5.3, Table 8
Added edit Q646 for any data point eligible for an exemption code.
“Your file indicates that at least one exemption code was used. Please verify that your institution is eligible for a partial exemption pursuant to the 2018 HMDA Rule.”
Section 5.3, Table 9
Added edit Q647 for exemption applicability for non-depository institutions.
“If Federal Agency equals 7, indicating a non-depository institution, exemption codes should not be used in the Loan/Application Register. Your data indicates that at least one exemption code was used.”
The full 2019 FIG can be found here.