In the July 21, 2016 issue of the Federal Register (81 FR 47394) (click here), the Federal Financial Institutions Examination Council (“FFIEC”) announced the availability of Filing Instructions Guides (“Guides”) for data collected pursuant to the Home Mortgage Disclosure Act (“HMDA”) for 2017 and 2018. The Guides for these upcoming years can be found at the Bureau of Consumer Financial Protection’s (“CFPB”) website at http://www.consumerfinance.gov/data-research/hmda/for-filers. The current guide, for HMDA data collected during 2016, can be accessed at the FFIEC’s website at http://www.ffiec.gov/hmda/guide.htm. These Guides provide instruction for HMDA’s collection and reporting requirements. Mortgage industry stakeholders are also reminded of the CFPB’s new HMDA rule that was issued on October 15, 2015 and will take effect on January 1, 2018 (a limited portion of the rule will take effect on January 1, 2017, which will exclude depository institutions originating fewer than twenty-five home purchase or refinance loans from HMDA’s coverage). Examples of changes created by this rule include changing HMDA’s coverage requirements to impose a uniform loan-volume threshold and increasing the number of reportable data points collected from loan applicants. In addition, entities will begin to submit their collected HMDA data to the CFPB instead of the FFIEC, starting with data collected during 2017 for submission in early 2018. The CFPB has added compliance resources to their website to aid institutions adjust to the upcoming implementation of this new HMDA rule. These resources can be found on the CFPB’s website at http://www.consumerfinance.gov/policy-compliance/guidance/implementation-guidance/hmda-implementation/. Resources include the complete text of the rule, a compliance guide for small entities, and a video overview of the rule recorded from a July 14, 2016 webinar. Although HMDA reporting changes will not take effect until January 1, 2018, we strongly encourage those in the mortgage industry to review the CFPB’s compliance materials soon so as to be fully prepared for the upcoming changes.
