Banking and Finance Law Daily FFIEC issues new HMDA guide
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Monday, March 25, 2019

FFIEC issues new HMDA guide

By Jeff Williams

A new guide released by the Federal Financial Institutions Examination Council provides an easy-to-use summary to Home Mortgage Disclosure Act requirements.

The Federal Financial Institutions Examination Council has released "A Guide To HMDA Reporting: Getting It Right!," intended to assist in complying with the Home Mortgage Disclosure Act, as implemented by the Consumer Financial Protection Bureau’s Regulation C, 12 CFR Part 1003. The guide is designed to be an "easy-to-use summary of certain key requirements" of Reg. C. The FFIEC noted that the guide "does not provide detailed information about the HMDA submission process, or file, data, and edit specifications."

The new version of the guide incorporates amendments made to the guide in the Dodd-Frank Act and the Economic Growth, Regulatory Relief, and Consumer Protection Act. The Dodd-Frank Act amended the HMDA by moving rule writing authority to the CFPB, and it also "expanded the scope of information that must be collected, reported, and disclosed" under the HMDA. The FFIEC notes that in 2015 the CFPB issued the HMDA Rule implementing Dodd-Frank Act amendments to Reg. C, and on Aug. 24, 2017, the CFPB issued a 2017 HMDA Rule that made technical correction and other amendments to clarify certain requirements adopted by the 2015 HMDA Rule.

The 2015 HMDA Rule also modified the "types of institutions and transactions subject to Reg. C, the types of data that institutions are required to collect, and the processes for reporting and disclosing the required data." In addition, the EGRRCPA included HMDA amendments that added partial exemptions from HMDA’s requirements "for certain transactions made by certain insured depository institutions and insured credit unions," the new guide said. The CBPB also issued a 2018 HMDA Rule to clarify and implement changes made by the 2018 Act.

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