Mon, Jul 31, 2017
The CFPB recently posted a couple of new resources to the HMDA implementation webpage that are worth reviewing if your credit union reports HMDA data. The CFPB made some updates to the technology preview, a system they are referring to as the "HMDA Platform" which will be available online only and is supposed to guide filers through the entire filing process. The preview provides some table views of the platform and gives us a better idea of what we can expect from the new data submission process, which is expected to be ready by the third quarter of 2017.
The platform will require every HMDA filer to register online for login credentials and establish an account. Once registered, the credit union can directly upload its LAR, check which stage it is in, complete the review and verification steps, then submit the LAR from within the platform. If the LAR is not properly formatted, the platform will display an error message and the filer must correct and refile the LAR. The CFPB has created a LAR Formatting Tool to help small institutions with smaller volumes of covered loans create a pipe delimited text file format that can be submitted on the platform. The Platform will identify any HMDA edits which must be addressed before the data can be submitted. Once all edits have been addressed, an authorized representative from the filer's institution must certify the completeness and accuracy of the LAR before submitting the LAR. After submission, the platform provides a confirmation screen acknowledging date and time of submission.
Other new tools on the HMDA website include two separate Filing Instructions Guides (FIG), one for data collected in 2017 (available here) and another for data collected in 2018 (available here). These guides replace the FFIEC's "Getting it Right!" guide that HMDA filers have relied on for so many years. The 2017 FIG is necessary to explain the new submission process because data collected in 2017 and reported in 2018 will be submitted to the CFPB for the first time, rather than to the Federal Reserve. The new data reporting requirements in the HMDA Final Rule apply to data collected beginning on January 1, 2018, so a separate 2018 FIG was created for that purpose.
With the HMDA effective date is fast approaching, we recommend that you take some time to familiarize yourself with these new reporting instructions and resources. There is a Frequently Asked Questions document specific to the filing process that is also helpful. Getting your credit union up to speed for HMDA compliance is a lengthy process and one that you should start preparing for sooner rather than later.