CFPB Issues Guidance and Reference Tools to Assist with Implementation of New HMDA Rule
The CFPB has recently updated and published multiple resources in order to assist the financial services industry as it prepares to submit the first set of reportable HMDA data in 2018.
The HMDA Small Entity Compliance Guide (“the Guide”) was updated in October to incorporate the content of the final HMDA rule, which was issued on August 24, 2017. The changes to the Guide are both substantive and administrative in nature. Some of the updates include changes to the reporting requirements, such as acceptable methods of reporting as well as reportable information, exclusions from coverage for temporary financing and preliminary transactions that consolidate new funds into a New York CEMA, updates to the effective date of enforcement provisions for larger volume reporters, clarifications in regards to securitizers and automated underwriter systems, as well as incorporation of information concerning what constitutes a loan secured by a multifamily dwelling and whether certain installment sales contracts are extensions of credit for purposes of the HMDA rule.
One of the most significant updates to the Guide, however, was the inclusion of an increase to the threshold for covered open-end lines of credit. Starting in 2018, there will be a temporary increase in the threshold for reporting the open-end lines of credit from 100 to 500 transactions in each of the proceeding two years. Therefore, financial institutions originating 100 or more open-end lines of credit, but fewer than 500 in 2018 or 2019 will not be required to collect or report data on those lines of credit until January 1, 2020.
The CFPB also recently published a new chart, titled Reportable HMDA Data: A regulatory and reporting overview reference chart. The chart combines the reportable data chart with the filing instructions from the 2018 Filing Instructions Guide, and the Reporting “Not Applicable” chart into one reference guide in order to consolidate all of this data for ease of reference.
In a further effort to inform the industry, the CFPB is also in the process of demonstrating to the industry how the new HMDA Platform will function for the collection of reportable HMDA data under the new rule. It stated in a recent announcement that the new HMDA Platform will be available to users this fall, 2017 in order to allow users time to explore the features prior to the first required submission of data.
More information on resources available to users in preparation for filing HMDA data in 2018 can be found here: https://www.consumerfinance.gov/data-research/hmda/for-filers.
