FFIEC Updates HMDA Technology Platform for Filing LAR
January 2017, the Federal Financial Institutions Examinations Council (FFIEC) updated its technology platform for filing the Loan Application Register (LAR) as required by the Home Mortgage Disclosure Act (HMDA). For HMDA data collected in or after 2017, a web-based data submission and edit-check system (the HMDA Platform) has been created to process HMDA data. The agency expects the HMDA Platform will streamline the LAR submission process and reduce burden on HMDA filers. The FFIEC has prepared a LAR Formatting tool to help financial institutions, typically those with small volumes of covered loans and applications, to create an electronic file that can be submitted to the HMDA Platform. The HMDA Platform will be available online only and will guide institutions through the entire filing process, including the review of any edits and the certification of the accuracy and completeness of the loan/application register (LAR). Please refer to the Resources provided below.
December 22, 2016, the CFPB Published an Informational Guide Letter which restated previously announced information related to the data collection under HMDA. The guide letter also included updated geographic designations. Key points from the letter are provided:
Asset-Exemption threshold The 2017 exemption threshold for depository institutions was not changed and will remain at $44 million. Thus, depository institutions with assets of $44 million or less as of 12/31/2016 are exempt from 2017 data collection. The exemption thresholds for nondepository institutions have not changed.
New Loan-Volume Threshold for Depository Institutions Changes to financial institution coverage go into effect beginning on January 1, 2017. On October 15, 2015, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C, which implements HMDA. The final rule narrows the scope of depository institutions subject to Regulation C in 2017. A depository institution will not be subject to Regulation C in 2017 unless it: (1) meets the current Regulation C asset-size, location, federally related, and loan activity tests, and (2) originated at least 25 home purchase loans, including refinancings of home purchase loans, (as those terms are defined in current Regulation C) in each of the two preceding calendar years (i.e., at least 25 in 2015 and at least 25 in 2016) The link to the completed guide letter are provided below.
RESOURCES
Technology Preview
http://www.consumerfinance.gov/data-research/hmda/tech-preview
Instructions for Using the Formatting Tool
Filing Instruction Guide for Data Collected in 2017
http://www.consumerfinance.gov/data-research/hmda/static/for-filers/2017/2017-HMDA-FIG.pdf
Filing instruction Guide for Data Collected in 2018
http://www.consumerfinance.gov/data-research/hmda/static/for-filers/2018/2018-HMDA-FIG.pdf
CFPB Informational Guide Letter
https://www.ffiec.gov/hmda/pdf/2017letter.pdf
Anna DeSimone founded Bankers Advisory in 1986 and is a nationally recognized authority in residential mortgage lending. She has received numerous industry awards and has authored more than 40 best practices guides and hundreds of articles.
WHERE is the link to HMDA Platform? I’ve reviewed all the links in the above info. We’ve use to file on the DES website