Submission - OCC -Small Filers - Denial Reasons

Any OCC small filers out there have or had issues submitting their data with the denial reasons being reported, while exempting the other allowable fields?

We're FDIC but we report the denial reason while exempting the other allowable fields. I had no issues.

What validity error code are you getting? That's not one that is listed in the 2018 FIG, and you are technically allowed to voluntarily report any data field (so long as you report all the associated fields), so you shouldn't be getting an error.

Thank you for your responses. Our software provider is afraid we would get error V711.

Well, V711 says that if you take the partial exemption for the Reasons for Denial fields, you need to report Code 1111 for Reasons for Denial 1, and then leave the remaining Reasons for Denial fields blank. That makes sense. It doesn't say you must take the exemption specifically for the Reasons for Denial fields.

I guess I'm not clear here, are you getting an error from the CFPB Platform, or from your vendor?

The vendor.

Well, I suppose there could just be a system limitation they are enforcing. But beyond that, technically you're not prohibited from reporting the Reasons for Denial even if you're taking the exemption for all the other fields.

ADN, I didn't see your PM from yesterday until this morning and I sent you the following reply and I'll post here just in case someone else is having a similar issue as you are.

All my exempt fields had either Exempt or 1111 in them or if applicable the field was left blank.

Denial Column 1 had either code 10 or the appropriate denial reason marked. Denial Columns 2, 3 & 4 had either the appropriate denial reason marked or left blank if not applicable.

I submitted using the CFPB HMDA Data Formatting Tool.

Thank you for your repy! I believe the vendor we utilize has finally seen the light and is reformatting their edits.

So I'm confused. We are fairly new to HMDA - on our 2nd year of submitting a LAR. We are a small filer. 1 Heloc in 2017 and no Helocs in the last year. 27 1-4 family loans in each of the previous two years (2017 & 2018). We are regulated by FDIC. Do we have to report the denied reason on the LAR?

HMDA 2018 Section 1003.4(a)(16) no longer provides an option to not report the denial reason that I can see.

a) Data format and itemization. A financial institution shall collect data regarding applications for covered loans that it receives, covered loans that it originates, and covered loans that it purchases for each calendar year. A financial institution shall collect data regarding requests under a preapproval program, as defined in § 1003.2(b)(2), only if the preapproval request is denied, is approved by the financial institution but not accepted by the applicant, or results in the origination of a home purchase loan. The data collected shall include the following items:

(16) The principal reason or reasons the financial institution denied the application, if applicable.

And from the 2018 GIR page 62:

5.11 Reason for denial

For an Application that it denied, a Financial Institution must report the principal reasons (up to four) that it denied the Application. 12 CFR 1003.4(a)(16); comment 4(a)(16)-1. For all other transactions, a Financial Institution reports that the data point is not applicable. Comment 4(a)(16)-4.

OOOPS. I forgot about the Interpretive Rule exempting this category for small filers.

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Dan is correct that the denial reasons aren't required for small filers using the partial exemption. That said, FDIC banks who are thrifts and savings associations (e.g. former OTS) must still report the denial reasons, just like they did before the new HMDA rules started in 2018.