On December 21, 2017, the CFPB announced that it does not intend to require Home Mortgage Disclosure Act (“HMDA”) data resubmission unless data errors are material or assess penalties with respect to errors in HMDA data collected as of January 1, 2018 and reported in 2019.
According to the statement any CFPB examinations of 2018 HMDA data will be diagnostic to help financial institutions identify compliance weaknesses and will credit good faith compliance efforts. The CFPB expects that the collection and submission of the 2018 HMDA data will provide financial institutions an opportunity to identify any gaps in their implementation of amended Regulation C and make improvements in their HMDA compliance management systems for future years.
The CFPB also announced it intends to open a rulemaking to reconsider various aspects of the 2015 Final HMDA rule, such as the institutional and transactional coverage tests and the rule’s discretionary data points.
If you have any questions regarding this CFPB announcement, please reach out to our Contact Attorney.
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