Roughly 1,700 financial institutions are affected by the CFPB’s HMDA threshold change. It means that as of January 3, 2023, a HMDA program should have been in place to collect and report the required data.
For most impacted institutions, this required training, in addition to reviewing, updating, or creating processes to collect and report HMDA data.
An ineffective or inadequate data collection process can lead to errors in reporting and regulators continue to cite significant HMDA data error rates. Mistakes or inaccuracies in your institution’s HMDA data report could lead to penalties or flag other fair lending or redlining issues for your institution.