CFPB Updates

In case you did not see:

1. The Bureau has updated the chart on the Collection and Reporting of HMDA Information about Ethnicity and Race.

2. The Bureau has published a new chart, Reportable HMDA Data: A Regulatory and Reporting Overview Reference (“Reporting Reference Chart”) intended to be used as a reference for data points required to be collected, recorded, and reported under Regulation C. The Reporting Reference Chart combines the contents of the Summary of Reportable Data and Reporting “Not Applicable” charts with the filing instructions for that data.

3. A revised Filing Instructions Guide (FIG) for data collected in 2018 has been issued that reflects updates to the Automated Underwriting System (AUS) and AUS results, guidance on reporting government monitoring information (GMI) collected on the basis of visual observation or surname for applicable loans, and other minor clarifications.

The charts are available on the HMDA implementation webpage. .

You can access the updated 2018 FIG on the Resources for HMDA Filers webpage.

4. Today, an email was sent out regarding the HMDA Platform for 2017 submissions. In case you were not on the distribution list, the email states:

"In response to inquiries received regarding the timeline for the release of the new HMDA Platform, we wanted to provide an updated status. The CFPB is currently demonstrating to industry the new HMDA Platform’s functionality and user experience through webinars, industry conferences, and in-person user testing sessions. A video version of the CFPB’s demonstration will be made available soon. The new HMDA Platform will be available to all users in Fall 2017 to explore its features prior to, in 2018, the first submission of data to the HMDA Platform.

The current schedule will still provide time for filers and vendors to interact with the new system prior to filing season.

Other resources available to users as they prepare for filing HMDA data in 2018 using the HMDA Platform include:

>The Filing Instructions Guide (FIG) for data collected in 2017 (PDF).
>The File Format Verification Tool that determines whether a file meets HMDA Platform filing requirement of (1) being pipe-delimited; (2) containing the proper number of data fields; and (3) containing integers, where necessary.
>The LAR Formatting Tool, an Excel-based resource potentially useful for those with lower volumes of loan activity.
>The Resources for Filers page where we will continue to post updates to the Technology Preview and FAQs.


If you have any questions or concerns please contact us at hmdahelp@cfpb.gov.

Thank you,

HMDA Operations Team
Consumer Financial Protection Bureau"

Someone has already noted that there is an unfortunate difference between the new "Reporting Reference Chart" and the FIG.

The FIG's first field for each transaction entry is the "Record Identifier" and that field isn't included in the Reporting Reference Chart. That might lead you to wonder whether there's an error in either the Reporting Reference Chart or the FIG, since each data point listed in the Reporting Reference Chart is numbered one less than the corresponding data point in Record 2 of the FIG. There is no error, although I agree that the Bureau could have avoided the question by starting the field numbers with "2"

They have been leaving that off all along. I think it is because it does not have to be added by the financial institutions. Vendor software adds it and the CFPB Excel LAR formatting tool does not call for it, it automatically adds it.

If you create your own file outside of their tool, you will need it unless you too build a macro that adds it.