FFIEC Issues HMDA Examiner Transaction Testing Guidelines

On August 23, 2017, the Federal Deposit Insurance Corporation (FDIC) issued Financial Institution Letter FIL 2017-36. The letter announces that the Federal Financial Institutions Examination Council (FFIEC) is issuing guidelines for examiners to use in assessing the accuracy of the Home Mortgage Disclosure Act (HMDA) data institutions record and report.

The HMDA Examiner Transaction Testing Guidelines (Guidelines) describe FFIEC procedures for sampling and validating HMDA data. The Guidelines should assist financial institutions seeking to better understand the approach the FDIC will use to assess HMDA data as part of the examination process.

Statement of Applicability to Institutions with Total Assets under $1 Billion:

This Financial Institution Letter applies to all FDIC-supervised institutions subject to HMDA and Regulation C. An HMDA exemption applies to institutions with assets at or below a threshold specified in Regulation C.

View the FIL-2017-36

View the HMDA Testing Guidelines

  • 781-402-6406

Marissa Blundell, JD, principal, services as CLA Bankers Advisory’s chief operating officer, overseeing all quality control and compliance assessment services. She is a graduate of Skidmore College and New England School of Law. She is admitted to the Massachusetts Bar. Marissa provides compliance training to clients, conducts public training webinars, and speaks at state and regional industry events. She is co-chair of the Massachusetts Mortgage Bankers Association Legislative Committee and is a member of the Mortgage Action Alliance Steering Committee and the national Mortgage Bankers Association's Quality Assurance Committee.

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