In a nutshell, to make sure everyone is aware of this. I have done webinars on this for BOL and my own clients, and I have blogged
about it - but I know there will be others who are not aware! So, in a nutshell:
1. The FFIEC data submission software will no longer be used after the 2016 HMDA submissions
2. The new platform will be online and files will be uploaded
3. Error corrections will not be made in the new online platform - correct in your spreadsheet or vendor software
4. The new platform will not be available until summer 2017
5. A temporary edit tool will be provided (look for it in January) for those who want to run edits on quarterly LAR without vendor software
6. All HMDA reporters must register, using vendor software - keep an eye out for announcements re registration
7. Edit process changes: Pre-submission, all edits including the macro edits (that now occur post-submission) must be cleared. Allow time for this. There will be no post-submission email with macro edits.
8. Errors must be corrected offline and a new corrected upload processed
9. An authorized person must certify (online) to the accuracy and completeness of the submission - last pre-submission step.
10. Resubmissions follow same process as original
11. Online submission will be only submission method - no paper, no mailing of disks or cds, no emailing of encryped files by financial institution or by vendor software
Stay up to date at CFPB resources for filers page: CFPB HMDA Technology Resources Page