On 6/24/2020, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of the 2019 HMDA data for 5,508 U.S. financial institutions. This data is used by the industry, consumer groups, regulators, and others to assess potential fair lending risk and for other purposes. In their release, the FFIEC pointed out a few observations.

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.

On December 20, 2019, the CFPB adjusted the HMDA exemption threshold from $46 million to $47 million.  The adjustment is based on the 1.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2019 (down from 2.6 last in 2018). Therefore, banks, savings associations, and credit unions with assets of $47 million or less as of Dec. 31, 2019, are exempt from collecting data in 2020.

As the new year is quickly approaching, we have continued to receive a number of questions regarding a potential final HMDA rule that would (possibly) increase the thresholds for reporting of both closed-end and open-end loans.  This, of course, could provide significant relief to HMDA reporters, especially those reporters who have fairly small HMDA LARs.

As the CFPM released their Fall regulatory agenda this week (11/20/19), the Bureau provided us with a bit of insight into their plans for two potential new HMDA rules that could provide significant relief…

On 9/25/19, the CFPB announced the availability of their Filing Instructions Guide (FIG) for data collected in 2020 is now available. The FIG is a technical resource to help financial institutions file HMDA data collected in 2020 and reported in 2021. In conjunction with this, the CFPB also announced…

We received a question this week about when to expect more HMDA changes.  That’s right, more HMDA changes are on the horizon, but we really don’t know when to expect them.  As we reported back in May of 2019, the CFPB has issued two things that could result in more HMDA changes: 1) a Notice of Proposed Rulemaking as well as 2) an Advance Notice of Proposed Rulemaking. This article provides a summary of the possible changes, what to look for, and a reminder that comments on both potential changes are due on October 15, 2019.