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FOS Blog

10 Aug
2018

Can I Stop Collecting Expanded HMDA Data?

Can I Stop Collecting Expanded HMDA Data?

On July 5 the CFPB issued a press release announcing the partial exemption for institutions who originated fewer than 500 closed-end or 500 open-end lines of credit in the preceding two years.  Since EGRRCPA said it was effective immediately, we began receiving questions about whether small institutions could revert to the old style of data collection or stop collecting data altogether.  That answer is a firm “No!”

Even though the statute had no waiting period, the CFPB still needs to write regulations telling us what data fields have changed.  Word on the street is that we are not reverting to the old LAR format.  Too much has been invested in bank software changes, CFPB software changes, re-training, and process changes to vacate all of that.  Most likely, the CFPB will develop a new code for the fields that won’t be reportable by those small institutions since “NA” (Not Applicable) is already in use.

Earlier in 2018, Mick Mulvaney had already announced that the CFPB was going to open rulemaking to reconsider institutional and transactional coverage tests and HMDA’s discretionary data points.  It is anticipated that the CFPB will roll the EGRRCPA changes into these revisions.

So, what can we expect?

  • Watch for a Notice of Proposed Rulemaking from the CFPB later this Fall with a short comment period!
  • Stay diligent with your current HMDA data collection.
  • Be prepared for a year-end or early 2019 HMDA crunch-time if revisions become effective for 2018 filing.

For additional information contact Evelyn at edehmey@fosaudit.com.

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