The Home Mortgage Disclosure Act (“HMDA”) requires many lenders to report information they receive from applications for certain types of mortgage loans and certain types of loans that they purchase. The Dodd-Frank Wall Street Reform and Consumer Protection Act tasked the CFPB with expanding the information collected under HMDA by including additional types of data, such as data regarding mortgage loan underwriting. In 2015, the CFPB issued a rule requiring that financial institutions collect and report additional mortgage data effective January 1, 2018. In its final rule issued in August, 2017, the CFPB clarified reporting requirements and increased the threshold for collecting and reporting data on home equity lines of credit to two years. 

On December 21, 2017, however, the CFPB publicly acknowledged the compliance challenges presented by this rule. For data collected in 2018 and reported in 2019, the CFPB stated it does not intend to require data resubmission, unless there are material errors, and does not intend to assess penalties for data errors. The CFPB hopes this will allow the collection and submission of HMDA information in 2018 to highlight any compliance gaps and provide financial institutions with the opportunity to remedy them.  

The CFPB also stated that it intends to engage in rulemaking to rethink portions of the 2015 HMDA rule. For now, though, financial institutions are to submit data collected in 2017 and reported in 2018 in accordance with the current Regulation C. Starting with HMDA data collected in 2017, financial institutions are to use the CFPB’s new online platform for items such as uploading loan and application registers, reviewing edits, and certifying data. 

To read the statement, visit: https://www.consumerfinance.gov/about-us/newsroom/cfpb-issues-public-statement-home-mortgagedisclosure-act-compliance/