CFPB Issues HMDA Changes Statement

• July 10, 2018
• CLA Regulatory Compliance Team

On July 5, 2018, the Consumer Financial Protection Bureau (CFPB) issued a statement regarding the recently announced changes to the Home Mortgage Disclosure Act (HMDA). Back on May 24, 2018, the President signed into law the Economic Growth, Regulatory Relief, and Consumer Protection Act (Act), which made changes to HMDA. These changes generally impact smaller financial Institutions and provide relief from data collection and reporting requirements that went into effect January 1, 2018.  The changes from the Act for smaller institutions has created a fair amount of confusion for financial institutions. The CFPB’s statement indicated that later this summer it will issue guidance on the changes and address specific applicability questions. Until then, the CFPB stated that for all institutions filing HMDA data collected in 2018, the Act will not affect the format of the Loan/Application Registers (LARs):

• LARs will be formatted according to the previously-released 2018 Filing Instructions Guide for HMDA Data Collected in 2018.
• If an institution does not report information for a certain data field due to the Act’s partial exemptions, the institution will enter an exemption code for the field specified in a release issued later this summer.
• All LARs will be submitted to the same HMDA Platform. A beta version of the HMDA Platform for submission of data collected in 2018 will be available later this year for filers to test.

The statement also explained that the CFPB does not intend to assess penalties with respect to errors in data collected in 2018 and reported in 2019 and that examinations of 2018 HMDA data will be intended to help institutions identify compliance weaknesses. The CFPB stated they will be looking for good-faith compliance efforts.

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