FFIEC Revises HMDA Examiner Transaction Testing Guidelines

The FFIEC has revised its Examiner Transaction Testing Guidelines (Guidelines) for testing and validating the accuracy and reliability of home mortgage loan data that will be reported under the Home Mortgage Disclosure Act (HMDA).  The revised procedures describe how to validate the accuracy of HMDA data collected beginning on January 1, 2018.

The new Guidelines establish guidelines based on a statistical sampling methodology.  Direction is provided to examiners in determining error rates for expanded data fields, such as applicant race and ethnicity.  Error rate thresholds are established determining when an institution is expected to correct and resubmit reported data.  The Guidelines also provide examples to demonstrate the application of procedures in specific cases.

The FFIEC members intend to incorporate the new transaction testing Guidelines into updated FFIEC HMDA examination procedures that reflect the revised requirements of the amended HMDA rule. Full updated HMDA examination procedures are in development.