The Federal Financial Institutions Examination Council (FFIEC) has issued the 2021 edition of A Guide to HMDA Reporting Getting it Right!, it can be found at ffiec.gov/hmda/guide.htm. This guide should be used for HMDA data collected in 2021 for submission by March 1, 2022. Do not wait until 2022 to start your 2021 HMDA data scrubs – contact Regulatory Solutions today and let us assist you in scrubbing your 2021 HMDA data utilizing our proprietary HMDA software. Regulatory Solutions will scrub your data to source documents and provide an exception report for your use with all data points that need to be corrected prior to submission. For additional information contact us email@example.com.
The filing of the 2020 HMDA LAR is in the books and I think everyone is thankful to have that behind them. The past year brought on new challenges for all of us, especially the mortgage industry with the sheer volume of new purchases and refinances – all while working remotely. This increase of mortgage file volume of course increased the amount of HMDA data to be reported for the year. Financial Institutions, as defined under Regulation C, that meet certain loan-volume thresholds for closed-end mortgage loans and for certain open-end lines of credit are required to submit their HMDA data annually and are required to submit that data correctly.
Last year, Regulatory Solutions reviewed over 21,000 HMDA files for financial institutions to ensure the data reported on their HMDA LAR was supported in their file and was recorded correctly. That is over 2.2 million actual data points reviewed and the results required over 50,000 data points to be corrected prior to submission. An analysis of the corrections needed in 2020 yielded the following top ten findings:
- Rate Spread
- Loan Amount (notably on non-originated files)
- Data points for certain loans subject to Regulation Z (i.e., origination fees, lender credits)
- Debt-to-income ratio
- Type of purchaser
- Visual Observation of applicants
- Submission of application
- Action Taken Date (notably on non-originated files)
- Automatic Underwriting System
Why is it important to scrub your HMDA data and make corrections prior to submission? The data on the HMDA LAR is used to help determine if the financial institution is serving its community housing need; to assist public officials in distributing public investment to attract private investment; and to assist in identifying any potential discriminatory lender patterns in order to enforce antidiscrimination statues and for this to be relevant data it must be correct. The Consumer Financial Protection Bureau, as well as the other regulatory agencies, will conduct transaction testing prior to starting a HMDA review to ensure the data is correct. If 10 percent or more of the HMDA LAR sample entries contain errors for a reporter with fewer than 100,000 entries the financial institution may be required to correct and resubmit the HMDA data; for reporters with greater than 100,000 entries correction and resubmission may be required with four percent or more of the sample entries containing errors.
To avoid having to resubmit, make sure you have the HMDA LAR correct at time of submission and the best time to start that HMDA scrub is now for the 2021 HMDA data. Regulatory Solutions can assist you with this by scrubbing your data on a monthly or quarterly basis and providing you with an exception report detailing each data point needing correction. Contact us today at 205-736-7717 to discuss how we can help you Get it Right.
Now that you have filed your 2020 HMDA LAR, it is time to get started scrubbing your 2021 HMDA Data. Let Regulatory Solutions help by scrubbing your 2021 HMDA LAR to source data using our proprietary HMDA Software. The data from a financial institution’s HMDA LAR is used to help determine if lenders are servicing the housing needs of its communities and provides public officials information to develop and allocate housing and community development investments – so it is important that you Get It Right! Contact us today to begin your 2021 HMDA LAR Data Scrub.
Now that you have filed your 2019 Home Mortgage Disclosure Act (“HMDA”) data, it is time to focus on 2020. The CFPB has issued the new 2020 Filing Instructions Guide (“FIG”) for submissions and data collection which can be found on the FFIEC website. The 2020 updates incorporate changes to the HMDA Rule issued by the Consumer Financial Protection Bureau in October 2019. The 2020 FIG can be found at https://www.ffiec.gov/hmda/guide.htm
While there are no substantial changes as to how you compile and submit your data, it is important to point out that we are seeing regulators requiring resubmissions and rescrubbing of HMDA data if it is not completed correctly. If you struggled with compiling and scrubbing last year’s HMDA data, Regulatory Solutions is here to help. Using our proprietary HMDA software, we compare your source documents in the loan file to the data points recorded on the HMDA LAR and provide you with an exception report detailing data points which need correction. Contact us today to begin your 2020 HMDA LAR Data Scrub.
The Federal Financial Institutions Examination Council (FFIEC) issued the 2020 “A Guide To HMDA Reporting: Getting it Right!”. This guide is to be used for HMDA Submissions due March 1, 2021. Regulatory Solutions, using its proprietary HMDA Software, has scrubbed over 9,000 HMDA loans/applications for financial institutions comparing the data on their 2019 and 2018 HMDA LARs to source documentation. Do not wait until 2021 to begin your HMDA scrub, contact Regulatory Solutions today. Let us provide your HMDA scrubs on either a monthly or quarterly basis so next year you will be ready to submit your HMDA LAR. The 2020 “A Guide To HMDA Reporting: Getting it Right!” can be accessed at https://www.ffiec.gov/hmda/guide.htm
The Consumer Financial Protection Bureau (“CFPB”) has published an updated HMDA Small Entity Compliance Guide. You can access the updated guide at https://www.consumerfinance.gov/policy-compliance/guidance/hmda-implementation/.
Regulatory Solutions specializes in helping you scrub your HMDA data to ensure the data you are submitting on your HMDA LAR is correct. Contact us to discuss how we can assist you in this process. Read more here >
On October 10, 2019, the CFPB issued a final rule that could affect your HMDA reporting for 2020. The first part of the rule extends the 500 threshold for open-end lines of credit until January 1, 2022. This means that institutions that originate fewer than 500 open-end lines of credit in the two preceding calendar years will not be required to report these lines of credit on their 2020 and 2021 LARS.
This final rule also incorporates the partial exemptions that were laid out in EGRRCPA into Regulation C. It also incorporates clarifications that smaller institutions have encountered when collecting their data to comply with the partial exemptions. Such as, whether a partial exemption applies after a merger or acquisition.
A copy of the final HMDA rule can be found below.
At Regulatory Solutions, we have developed HMDA software in order to complete full HMDA scrubs, including for those who qualify for partial exemptions.
What percentage of loans or applications on the HMDA LAR should I scrub?
This is a question we get asked quite often and my response is that you should look to the percentage examiners scrub. The Federal Financial Institutions Examination Council’s (FFIEC) HMDA Examiner Transaction Testing Guidelines (Guidelines) describe the validation process which examiners use and the circumstances in which examiners may direct institutions to correct and resubmit HMDA data. The examiners select a random sample of loans/applications to test using the following sample sizes and thresholds as indicated in the Guidelines at https://files.consumerfinance.gov/f/documents/201708_cfpb_ffiec-hmda-examiner-transaction-testing-guidelines.pdf:
|Total Sample Size (A)||Initial Sample Size (B)||Initial Sample Threshold (C)||Resubmission Threshold (D)|
*If less than 30 LAR lines, the institution should use the full sample size and the resubmission threshold remains at 3.
Let us scrub your HMDA data against source documents and provide you with an exception-based report indicating the percentage of errors by data point. You select your sample size either using the Guidelines or a certain percentage of HMDA loans/applications. Contact us today to discuss your HMDA scrub.
The CFPB recently issued a consent order against Freedom Mortgage Corporation for HMDA violations. These violations mainly revolved around the collection and reporting of applicant’s demographic information and spanned four years of HMDA reporting. Specifically, the Corporation was found to have violated Regulation C by:
- Selecting non-Hispanic white for the applicant’s race and ethnicity if the applicant did not provide the information for applications taken over the phone, regardless of the accuracy of the information.
- For applications taken over the phone, they misreported the applicant’s ethnicity and race as non-Hispanic white even when the applicants provided different information.
- Rather than addressing an internal system issue that would eliminate certain information if the applicant’s sex was not provided, the Corporation selected a sex for the applicant regardless of the accuracy.
None of the errors made by the Corporation were considered to be bona fide errors as allowed by Reg C. 1003.6(b)(1) which states that a bona fide error is an error in compiling or recording data that was unintentional and occurred despite procedures in place to avoid such an error. Among other orders, the Corporation was ordered to develop and maintain new policies and procedures to ensure accurate collection and reporting of their HMDA data. They also must pay a $1.75 million civil money penalty for these violations.
Regulatory Solutions has developed proprietary software to scrub and verify the data in your HMDA LAR. Please contact us today to discuss how we can help you to ensure that your HMDA data is correct.
The CFPB issued a proposed rule on May 2, 2019 that would change the HMDA reporting requirements and could have a significant impact on smaller financial institutions. The proposed rule would increase the closed-end coverage threshold from 25 to 100 loans originated in the previous two years. Additionally, it proposes to extend the current open-end threshold of 500 lines of credit until January 1, 2022. The proposed rule would also incorporate new interpretations and procedures into Regulation C. If this were to become part of the HMDA regulation, it would not take effect until January 1, 2020.