HMDA Resource Center
Introduction
Welcome to the HMDA Resource Center, a one-stop shop for the CFPB's amendments to the Home Mortgage Disclosure Act (HMDA) reporting requirements, providing access to Buckley’s analysis of the amendments, developments surrounding the amendments and other materials that will facilitate implementation of the amendments. Like our Know Before You Owe TRID Resource Center, CFPB Resource Center and other resource centers, this page will be updated as new materials become available.
Thought Leadership & Analysis
CFPB publishes 2019 reportable HMDA data reference chart
On January 31, the CFPB published a new reference chart titled “ Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for Data Collected in 2019 .” The chart is designed to be used as a reference tool for required data points to be collected, recorded, and reported under...
InfoBytesAgencies issue guidance on 37 key data fields for HMDA examinations
On December 7, the Federal Reserve Board, the FDIC, and the OCC issued guidance regarding the HMDA key data fields that Federal Reserve examiners use to evaluate the accuracy of HMDA data collected since January 1 pursuant to the CFPB’s October 2015 and August 2017 amendments and the May 2018...
InfoBytesCFPB updates HMDA Small Entity Compliance Guide
On October 30, the CFPB released an updated HMDA Small Entity Compliance Guide to reflect Section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act) and the 2018 HMDA interpretive and procedural rule. As previously covered by InfoBytes , on August 31, the CFPB...
InfoBytesCFPB publishes fall 2018 rulemaking agenda
On October 17, the Office of Information and Regulatory Affairs released the CFPB’s fall 2018 rulemaking agenda . According to the Bureau’s preamble , the information presented is current as of August 30 and represents regulatory matters it “reasonably anticipates” having under consideration during...
InfoBytesFDIC FIL provides guidance on HMDA partial exemptions
On October 10, the FDIC issued FIL-58-2018 which summarizes guidance provided by the CFPB on the implementation of partial exemptions from certain of HMDA’s reporting requirements for specific insured depository institutions and insured credit unions pursuant to Section 104(a) of the Economic...
InfoBytes"The Home Mortgage Disclosure Act: Common compliance challenges" by Sherry-Maria Safchuk and Frida Alim (The Review of Banking & Financial Services)
Since 2015, financial institutions have been inundated with reviewing and implementing numerous changes to the Home Mortgage Disclosure Act (“HMDA”) as required by the Dodd-Frank Act. The act transferred HMDA rulemaking authority to the Bureau of Consumer Financial Protection (“Bureau”), added new...
ArticlesCFPB announces HMDA File Format Verification Tool and new 2017 data reports and datasets
On August 9, the CFPB released the 2018 File Format Verification Tool (FFVT). The FFVT tests whether HMDA reporters’ files meet formatting requirements, specifically whether the file (i) is pipe-delimited; (ii) has the proper number of data fields; and (iii) has data fields formatted as integers,...
InfoBytesWarren W. Traiger quoted in American Banker article, “Relief from HMDA requirements may go further than banks realize”
Warren T. Traiger was quoted on August 2, 2018 in an American Banker article, “Relief from HMDA requirements may go further than banks realize,” which discussed the Home Mortgage Disclosure Act reform and the recent clarification from a FDIC official regarding data collection for small lenders. The...
In The NewsFederal Reserve Board launches inaugural Consumer Compliance Supervision Bulletin
On July 26, the Federal Reserve Board released its inaugural Consumer Compliance Supervision Bulletin (Bulletin) to share information about the agency’s supervisory observations and other noteworthy developments related to consumer protection, and provide practical steps for banking organizations...
InfoBytesCFPB, OCC, and FDIC release statement on HMDA exemption in regulatory relief act
On July 5, the CFPB issued a statement regarding the implementation of the partial HMDA exemptions in the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act), S.2155/ P.L. 115-174, which was signed into law by President Trump on May 24. As previously covered by InfoBytes , the...
InfoBytesWarren W. Traiger quoted in American Banker article, “CFPB’s Mulvaney plots HMDA rollback, but it may not matter”
Warren Traiger was quoted on May 25, 2018 in an American Banker article, “CFPB’s Mulvaney plots HMDA rollback, but it may not matter,” which discussed acting director of the Consumer Financial Protection Bureau Mick Mulvaney's remarks to scale back Home Mortgage Disclosure Act requirements,...
In The NewsAndrea K. Mitchell quoted in American Banker article, “Will HMDA data carve-out for small banks make discrimination easier?”
Andrea K. Mitchell was quoted on March 13, 2018 in an American Banker article, “Will HMDA data carve-out for small banks make discrimination easier?” which discussed the Senate bill that seeks to exempt banks and credit unions from reporting expanded data as required by the Home Mortgage Disclosure...
In The NewsSenate passes bipartisan financial regulatory reform bill
On March 14, by a vote of 67-31, the Senate passed the Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155) (the bill)—a bipartisan regulatory reform bill crafted by Senate Banking, Housing, and Urban Affairs Committee Chairman Mike Crapo, R-Idaho—that would repeal or modify...
InfoBytesGAO recommends the CFPB review the effectiveness of TRID guidance for small institutions
On February 27, the U.S. Government Accountability Office (GAO) released a report of recommendations to financial regulators on actions to take related to the compliance burdens faced by certain small financial institutions. The report is the result of a study the GAO initiated with over 60...
InfoBytesFFIEC releases 2018 HMDA reporting guide
On February 21, the Federal Financial Institutions Examination Council (FFIEC) issued the 2018 edition of the “ A Guide to HMDA Reporting: Getting it Right! ” which reflects updates to the Home Mortgage Disclosure Act (HMDA) rule, effective January 1, 2018. The HMDA reporting guide is updated...
InfoBytesCFPB releases HMDA formatting tool and updates filing instructions
On February 1, the CFPB launched their 2018 Loan/Application Register (LAR) Formatting Tool (the “Tool”). According to the website, the Tool is intended to assist small volume lenders in creating an electronic file to submit to the HMDA Platform . The Tool is only intended to be used by...
InfoBytesHouse passes HMDA relief for small banks
On January 18, by a vote of 243-184, the House passed H.R. 2954 , to amend HMDA to exempt low-volume mortgage lenders from certain disclosure requirements. If enacted, the bill would exempt depository institutions from maintenance of records and disclosure requirements if, (i) for closed-end...
InfoBytesOCC highlights supervisory priorities in fall 2017 semiannual risk report
On January 18, the OCC announced the release of its Semiannual Risk Perspective for Fall 2017 , identifying key risk areas for national banks and federal savings associations. Top supervisory priorities will focus on credit, operational, and compliance risk. As previously discussed in the spring...
InfoBytesBuckley Sandler Insights: OMB releases updated and possibly outdated CFPB rulemaking agenda
OMB has released the CFPB’s Fall 2017 rulemaking agenda. Although this is the first update to the agenda since Richard Cordray left the agency in November 2017, delays in the publication of rulemaking agendas are common so the updated agenda may not reflect the views of new CFPB leadership. The...
InfoBytesCFPB Releases HMDA Tools; Updates HMDA Asset Threshold
On December 27, the CFPB announced the launch of a HMDA Check Digit Tool and a Rate Spread Calculator to assist financial institutions in the calculation of data field values required for reporting HMDA data. According to the CFPB, the HMDA Check Digit Tool and the Rate Spread Calculator will...
InfoBytesBenjamin K. Olson Quoted in Bankrate Article, “Borrowers Beware: These Mortgage Rules Could Soon Get a Face-Lift”
Benjamin K. Olson was quoted on December 22, 2017 in a Bankrate article, “Borrowers Beware: These Mortgage Rules Could Soon Get a Face-Lift,” which discussed the potential policy changes to mortgage rules including HMDA, TRID, and ability-to-repay under the new acting CFPB director Mick Mulvaney...
In The NewsArguments Heard in English Litigation; CFPB Announces Relaxed Compliance Requirements for HMDA; Other Proposed Rulemakings
On December 22, Judge Timothy Kelley heard arguments from both parties related to Leandra English’s litigation against President Trump and Mick Mulvaney. Judge Kelley did not rule on the matter at the close of the hearing. As previously covered by InfoBytes , English filed an amended complaint for...
InfoBytesFederal Reserve Repeals Reg C and Amends Reg M to Reflect CFPB Rulemaking Authority
The Federal Reserve Board (Fed) issued a final rule on December 22 to repeal Regulation C, Home Mortgage Disclosure (HMDA), and a proposed rule to amend Regulation M, Consumer Leasing Act (CLA) to reflect the transfer of certain rulemaking authority to the CFPB. Regulation C is being repealed...
InfoBytesSenate Banking Committee Approves Financial Regulatory Relief Bill
On December 5, the Senate Banking Committee approved bill S. 2155 , Economic Growth, Regulatory Relief, and Consumer Protection Act , which would alter certain financial regulations under the Dodd-Frank Act of 2010. While not as sweeping as previous legislative relief proposals (see previous...
InfoBytesFederal Banking Agencies Amend CRA Regulations to Conform With HMDA Regulation Changes
On November 24, the Federal Reserve Board, FDIC, and OCC published a joint final rule in the Federal Register , amending their respective Community Reinvestment Act (CRA) regulations. The amended regulations conform with the CFPB’s amendments to Regulation C, which implements the Home Mortgage...
InfoBytesCFPB Updates HMDA Implementation Materials; Federal Regulatory Agencies Release Key Data Fields
On October 17, the CFPB published a new reference chart titled “ Reportable HMDA Data: A Regulatory and Reporting Overview Reference ” designed to be used as a reference tool for required data points to be collected, recorded, and reported under Regulation C. The chart takes into account HMDA rules...
InfoBytesFDIC to Host Teleconference on HMDA Implementation
On October 26, the FDIC’s Division of Depositor and Consumer Protection is scheduled to host a teleconference that will focus on the implementation of the 2015 HMDA Final Rule requirements scheduled to take effect January 1, 2018. The FDIC encourages financial institutions to submit questions prior...
InfoBytesCFPB Publishes Updated Reference Material for HMDA
On September 28, the CFPB released, on its website, updates to the reference material for the Home Mortgage Disclosure Act (HMDA). The Bureau updated the, (i) institutional coverage criteria ; (ii) transactional coverage criteria ; and (iii) key dates timeline . These updates are associated with...
InfoBytesCFPB Announces Final Rule Modifying ECOA Regulations, Seeks Public Comment on Proposed Disclosure of HMDA Data
On September 20, the CFPB announced its Final Rule amending Regulation B, which implements the Equal Credit Opportunity Act (ECOA), as well as a notice of proposed policy guidance requesting public comment on modifications to loan-level HMDA data that will be made publicly available beginning in...
InfoBytesCFPB’s Summer Edition of Supervisory Highlights Discloses Findings Across Many Financial Services Areas
On September 12, the CFPB released its summer 2017 Supervisory Highlights , which outlines its supervisory and oversight actions in areas such as auto loan servicing, credit card account management, debt collection, deposit account supervision, mortgage origination and servicing, remittances,...
InfoBytesAgencies Issue Proposed Rulemaking to Amend CRA Regulations to Conform With HMDA Regulation Changes
On September 13, the Federal Reserve Board, the FDIC, and the OCC (Agencies) issued a joint notice of proposed rulemaking to amend Community Reinvestment Act (CRA) regulations to conform to the CFPB’s changes to Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The proposed...
InfoBytesFFIEC Releases Guidelines on HMDA Data Testing and Resubmission Standards
Earlier this week the Federal Financial Institutions Examination Council (FFIEC) issued new FFIEC Home Mortgage Disclosure Act Examiner Transaction Testing Guidelines (guidelines). Examiners will use the new guidelines to assess the accuracy of the HMDA data recorded and reported by financial...
InfoBytesCFPB Issues Final Rule Amending 2015 HMDA Rule
On August 24, the CFPB issued a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA) . The changes are primarily for the purpose of clarifying the new data collection and reporting requirements published in October 2015, with most of the clarifications and...
InfoBytesABA, State Banking Associations Request HMDA Implementation Delay
Following up on comments submitted to the CFPB on its proposal to amend the 2015 HMDA rule ( see previous InfoBytes coverage here ), the American Bankers Association (ABA)—along with state banking associations representing all 50 states and Puerto Rico—sent a letter on July 12 to the Bureau...
InfoBytesFinancial Services Associations Comment on CFPB’s HMDA Proposal
As previously covered in an InfoBytes Special Alert , the CFPB issued a request for comment on its proposal to amend the 2015 HMDA rule, which would incorporate changes primarily for the purpose of clarifying data collection and reporting requirements. The request, which closed for public comment...
InfoBytesLegislation Proposed to Require Study on Homeowners’ Privacy of Collected HMDA Information
On April 27, Reps. Randy Hultgren (R-Ill.) and Andy Barr (R-Ky.) reintroduced legislation to “protect against the misuse of consumers’ sensitive financial information” collected under the Home Mortgage Disclosure Act (HMDA). According to a May 5 press release issued by Rep. Hultgren’s office, the...
InfoBytesAmerican Bankers Association White Paper Addresses Concerns Over HMDA Expansion
On May 2, the American Bankers Association (ABA) issued a white paper to the Treasury Department on the implementation of the 2015 Home Mortgage Disclosure Act (HMDA) rule as part of its continuing response to President Trump’s executive order outlining “core principles” for financial regulation (...
InfoBytesFHFA Director Appeared Before the Senate Banking Committee on May 11; Discussed Fannie/Freddie, Proposed "Underserved Markets Plans"
On May 11, the Senate Committee on Banking, Housing, and Urban Affairs met in open session at 10:00 a.m. to discuss “The Status of the Housing Finance System After Nine Years of Conservatorship.” Federal Housing Finance Agency (FHFA) Director Mel Watt was the only witness scheduled to testify. The...
InfoBytesFollowing Hearing, House Financial Services Committee Chairman Formally Introduces Financial CHOICE Act of 2017
On April 26, the House Financial Services Committee held a hearing to discuss The Financial CHOICE Act – a GOP proposal to “reform the financial regulatory system” that was initially introduced and considered, though differing in a number of respects from the current version, but not adopted in the...
InfoBytesWarren W. Traiger Authored an American Banker Article, "Regulators' Silence on New HMDA Rule is Deafening"
As banks prepare to comply with a Consumer Financial Protection Bureau rule adding new reporting requirements under the Home Mortgage Disclosure Act, much attention has been paid to how expanded data points such as “interest rate” and “credit score” will affect fair-lending compliance. But the...
ArticlesSpecial Alert: CFPB Proposes Amendments to 2015 HMDA Rule
On April 13, the Consumer Financial Protection Bureau (CFPB) issued a proposal to amend the 2015 Home Mortgage Disclosure Act (HMDA) rule. The changes are primarily for the purpose of clarifying data collection and reporting requirements, and most of the clarifications and revisions would take...
InfoBytesSpecial Alert: CFPB Proposes Amendments to 2015 HMDA Rule
On April 13, the Consumer Financial Protection Bureau (CFPB) issued a proposal to amend the 2015 Home Mortgage Disclosure Act (HMDA) rule. The changes are primarily for the purpose of clarifying data collection and reporting requirements, and most of the clarifications and revisions would take...
ArticlesCFPB Proposes Amendment to Regulation C to Clarify HMDA Rule
On April 13, the CFPB announced the release of its proposal to amend Regulation C (12 CFR Part 1003), the regulation that implemented the Home Mortgage Disclosure Act (HMDA) and requires lenders to collect, report and disclose data on home loan applications, originations, and purchases of mortgage...
InfoBytesFDIC Releases Third Volume in its Affordable Mortgage Lending Guide
On April 6, the FDIC released the third volume of its Affordable Mortgage Lending Guide ( Guide ). The Guide is designed to help community bankers understand and compare various affordable mortgage-related programs, as well as their Community Reinvestment implications. This third installment of the...
InfoBytesCFPB Releases Second Webinar on New HMDA Rule
On February 14, the CFPB announced the availability of a second Webinar on the New Home Mortgage Disclosure Act (HMDA) Rule (amending Regulation C), a Rule that was itself finalized in late 2015 but that is predominantly not effective until January 1, 2018, or later. The new Webinar, with audio and...
InfoBytesSpecial Alert: President Signs Executive Order Calling For Review of Financial Regulations
On February 3, President Trump signed an executive order (the Executive Order) directing the Treasury Secretary and the heads of the member agencies of the Financial Stability Oversight Council (FSOC) to review financial laws and regulations—including the Dodd-Frank Act and regulations implementing...
InfoBytesCFPB Releases Annual Report to Congress on Transparency, Accountability in 2016
On January 3, the CFPB announced the release of its annual report to the Senate and House Committees on Appropriations for 2016 . The report—which covers October 1, 2015 through September 30, 2016—identifies the specific responsibilities that the Dodd-Frank Act tasked to the CFPB and explains how...
InfoBytesCFPB Mortgage Servicing Rule Published in Federal Register
Last week, the CFPB’s final rule amending the mortgage servicing provisions of Regulations X and Z was published in the Federal Register . The amendments were previously covered in BuckleySandler’s August 9 Special Alert . The majority of the final rule will take effect on October 19, 2017, exactly...
InfoBytes5 Tips to Prepare for New HMDA Reporting
Last October, the Consumer Financial Protection Bureau published a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act. The CFPB drafted the amendments in response to specific congressional directives in the Dodd-Frank Wall Street Reform and Consumer Protection Act,...
ArticlesSpecial Alert: CFPB Proposes Amendments to Know Before You Owe/TRID Rule
On Friday, the CFPB issued its much anticipated proposal to amend the KBYO/TRID rule. The CFPB crowded dozens of proposed changes into the almost 300 page proposal, most of which are highly technical and require careful examination. As the Bureau has signaled since its intention to issue amendments...
InfoBytesSpecial Alert: CFPB Adopts Significant Expansion of HMDA Reporting Requirements
On October 15, the Consumer Financial Protection Bureau (the CFPB or Bureau) issued a final rule that will expand the scope of the Home Mortgage Disclosure Act (HMDA) data reporting requirements while seeking to streamline certain existing requirements. Although some of the new data points the...
InfoBytes
Regulatory Resources
HMDA Final Rule & Amendments
CFPB Guidance
- HMDA: Entire Rule
- HMDA: Executive Summary
- HMDA: Key Dates Timeline
- HMDA: Compliance Guide
- HMDA: Reference Guide on Reporting "Not Applicable" Information
- HMDA: Summary of Reportable Data