If a partial exemption applies to a covered transaction, an
insured depository institution or insured institution may,
but is not required to, collect, record and report these 26
data points. However, the insured depository institution
or insured institution must collect, record and report the
remaining 22 data points as required by the HMDA Rule,
and otherwise comply with the HMDA for such covered
transactions.
Section 5 of the guide provides an expanded discussion
of reportable data points.
Collection and Reporting of Applicant Information
(Section 2.4)
For data collected on or after Jan. 1, 2018 (to be
reported in or after 2019), the HMDA Rule amends the
requirements for collection and reporting of information
regarding an applicant’s or borrower’s ethnicity, race
and sex. It also adds a requirement to report how the
institution collects this information. A financial institution
can report whether or not it collected the information on
the basis of visual observation or surname.
Attachment A of the guide includes the new sample
data collection form providing the required aggregated
categories and disaggregated subcategories for ethnicity
and race.
Section 6 of the guide provides an expanded discussion
of recording requirements.
Annual Reporting (Section 2.5)
The HMDA Rule retains the requirement that a financial
institution must submit its HMDA data to its appropriate
federal agency by March 1 following the calendar year for
which it collected the data.
Beginning Jan. 1 2019, financial institutions were
required to submit the new data set electronically in
accordance with the HMDA Rule, using the new web-
based submission tool and revised procedures available
at http://ffiec.cfpb.gov/.
Section 6 of the guide provides an expanded discussion
of annual reporting.
Quarterly Reporting (Section 2.6)
HMDA data for each of the first three quarters of the year
on a quarterly basis beginning in 2020.
Section 6 of the guide provides an expanded discussion
of quarterly reporting.
Disclosure Requirements (Section 2.7)
Effective Jan. 1, 2018 for data collected on or after Jan.
1, 2017 (to be reported in or after 2018), the HMDA
Rule replaces Regulation C’s requirements to provide
a disclosure statement and modified loan application
register (LAR) to the public upon request with new
requirements to provide notices that the institution’s
disclosure statement and modified LAR are available on
the CFPB’s website.
The HMDA Rule also modifies the content of the posting
required under Regulation C.
Section 6 of the guide provides an expanded discussion
of modified LAR, public disclosure statement and posted
notice requirements. Attachment C of the guide provides
model posting notices.
Enforcement Provisions (Section 2.8)
Beginning Jan. 1, 2020, the HMDA Rule provides
inaccuracies or omissions in quarterly reporting are
not violations of HMDA or Regulation C, if the financial
institution makes a good-faith effort to report quarterly
data timely, fully and accurately, and then corrects or
completes the data prior to its annual submission.
Section 7 of the guide provides an expanded discussion
of HMDA enforcement.
Additional Topics
Section 8 of the guide address mergers and acquisitions,
while Section 9 focuses on practical implementation and
compliance recommendations.
In addition to leveraging this guide, consider using the
updated Regulatory and Reporting Overview Reference
Chart for HMDA Data Collected as a resource. lll
Note: The term “HMDA Rule” as used in the compliance guide refers collectively to the final
HMDA rules released in 2015, 2017, 2018 and 2019; thus, although the guide has just been
released, much of the content in the guide has already been analyzed and, as applicable for your
institution, implemented.
The HMDA Rule imposes a new quarterly reporting
requirement for larger-volume reporters effective Jan. 1,
2020. In addition to their annual data submission, these
larger-volume reporters will also electronically submit their
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