OCC, FDIC, and CFPB Pledge HMDA Leniency

On December 21, the OCC, FDIC and CFPB each announced that they do not intend to require resubmission of Home Mortgage Disclosure Act (HMDA) data for non-material data errors. They also do not intend to assess penalties for errors in HMDA data collected in 2018 and reported in 2019.  The leniency by the agencies is due in part to the major operational challenges that the 2015 HMDA rule poses to financial institutions and the fact that full compliance by the January 1, 2018 deadline is not a certainty for many financial institutions.  The agencies expect financial institutions to use the collection and reporting of 2018 data as an opportunity to identify and correct HMDA program gaps and deficiencies.

The CFPB also announced their intent to issue amendments to the 2015 HMDA rule.   The amendments could readdress lending activity criteria that determine whether financial institutions are required to report mortgage data. In addition, the amendments may adjust the new requirements to report certain types of transactions.




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John Zasada is a principal with CLA and leads the firm’s financial institution regulatory compliance practice. He assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, training staff on regulations, and performing website compliance assessments. In addition, John is a frequent speaker at industry conferences and state associations. Prior to joining CLA, he served as managing director at a top-10 accounting firm and as the compliance officer of a large financial institution, where he developed and implemented its first regulatory compliance program.

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