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Federal Agencies Slow Down HMDA Reporting Requirement

In late December, the CFPB and FDIC released identical public statements regarding the implementation of the CFPB's 2015 rule concerning the Home Mortgage Disclosure Act rule. The agencies explained that due to the significant systems and operational challenges needed to adjust to the revised Regulation C, the Bureau does not intend to require re-submission of data collected in 2018 and reported in 2019 unless there are material errors. The Bureau also does not plan on assessing penalties with respect to errors in data reported in 2019.

For the past several years, CSBS and the State Liaison Committee of the FFIEC have worked to ensure that changes to HMDA are implemented in a way that does not impose unneeded responsibilities for small reporters. The states have pushed hard for an inter-agency approach to supervision for HMDA, and the CFPB-FDIC statement is reflective of this approach.

Here is the agencies' statement:

"Statement with respect to HMDA implementation

"Recognizing the impending January 1, 2018 effective date of the Bureau’s amendments to Regulation C and the significant systems and operational challenges needed to adjust to the revised regulation, for HMDA data collected in 2018 and reported in 2019 the Bureau does not intend to require data re-submission unless data errors are material.

"Furthermore, the Bureau does not intend to assess penalties with respect to errors in data collected in 2018 and reported in 2019. Collection and submission of the 2018 HMDA data will provide financial institutions an opportunity to identify any gaps in their implementation of amended Regulation C and make improvements in their HMDA compliance management systems for future years. Any examinations of 2018 HMDA data will be diagnostic to help institutions identify compliance weaknesses and will credit good faith compliance efforts.

"The Bureau intends to engage in a rule-making to reconsider various aspects of the 2015 HMDA Rule such as the institutional and transactional coverage tests and the rule’s discretionary data points. For data collected in 2017, financial institutions will submit their reports in 2018 in accordance with the current Regulation C using the Bureau’s HMDA Platform."

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