Category: HMDA Alerts

The Consumer Financial Protection Bureau (“CFPB”) has published its 2023 Regulatory and Reporting Overview Reference Chart for HMDA. This resource chart is used for filing and scrubbing HMDA data for calendar year 2023. The 2023 HMDA reference chart can be accessed at www.consumerfinance.gov/compliance/compliance-resources/mortgage-resources/hmda-reporting-requirements/. It is never too early to start scrubbing your 2023 HMDA LAR. Regulatory Solutions offers independent audits/scrubs of your HMDA LAR on a monthly, quarterly or annual basis. Please contact us today to learn more about our HMDA scrub process. Contact either Betsy.reynolds@regulatorysol.com or Rhonda.Wannemuehler@regulatorysol.com to get started!

On September 23, 2022, the United States District Court for the District of Columbia vacated the increased loan-volume reporting threshold for closed-end mortgage loans in the 2020 HMDA Rule. As a result, the closed-end mortgage loan reporting threshold is 25 mortgage loans in each of the two preceding calendar years – the threshold established by the 2015 HMDA Rule. The amendment issued by the CFPB which reflects the recent decision can be found at:www.consumerfinance.gov/rules-policy/final-rules/hmda-reg-c-judicial-vacatur-of-coverage-threshold-for-closed-end-mortgage-loans/

If you originated 25 or more closed-end mortgage loans in the previous two years and find that you will now need to report your HMDA data, let us help you get your HMDA data ready for reporting with our proprietary HMDA Software and experienced analysts.

The countdown is on until March 1, 2023, and you know what that means. If you haven’t already, it’s time to get started scrubbing your 2022 HMDA LAR data. Let Regulatory Solutions help. Using our proprietary HMDA software, we can tailor HMDA scrubs to meet your business needs, objectives and budget. Whether you need monthly, quarterly or a one time HMDA scrub, contact Betsy.reynolds@regulatorysol.com or Rhonda.Wannemuehler@regulatorysol.com to get started today!

The Federal Financial Institutions Examination Council (FFIEC) has issued the 2021 edition of A Guide to HMDA Reporting Getting it Right!, it can be found at ffiec.gov/hmda/guide.htm.  This guide should be used for HMDA data collected in 2021 for submission by March 1, 2022.  Do not wait until 2022 to start your 2021 HMDA data scrubs – contact Regulatory Solutions today and let us assist you in scrubbing your 2021 HMDA data utilizing our proprietary HMDA software.  Regulatory Solutions will scrub your data to source documents and provide an exception report for your use with all data points that need to be corrected prior to submission.  For additional information contact us rhonda.wannemuehler@regulatorysol.com.

The filing of the 2020 HMDA LAR is in the books and I think everyone is thankful to have that behind them.  The past year brought on new challenges for all of us, especially the mortgage industry with the sheer volume of new purchases and refinances – all while working remotely.  This increase of mortgage file volume of course increased the amount of HMDA data to be reported for the year.  Financial Institutions, as defined under Regulation C, that meet certain loan-volume thresholds for closed-end mortgage loans and for certain open-end lines of credit are required to submit their HMDA data annually and are required to submit that data correctly.

Last year, Regulatory Solutions reviewed over 21,000 HMDA files for financial institutions to ensure the data reported on their HMDA LAR was supported in their file and was recorded correctly.  That is over 2.2 million actual data points reviewed and the results required over 50,000 data points to be corrected prior to submission.  An analysis of the corrections needed in 2020 yielded the following top ten findings:

• • Rate Spread
  • Loan Amount (notably on non-originated files)
  • Data points for certain loans subject to Regulation Z (i.e., origination fees, lender credits)
  • Debt-to-income ratio
  • Type of purchaser
  • Visual Observation of applicants
  • Income
  • Submission of application
  • Action Taken Date (notably on non-originated files)
  • Automatic Underwriting System

Why is it important to scrub your HMDA data and make corrections prior to submission?  The data on the HMDA LAR is used to help determine if the financial institution is serving its community housing need; to assist public officials in distributing public investment to attract private investment; and to assist in identifying any potential discriminatory lender patterns in order to enforce antidiscrimination statues and for this to be relevant data it must be correct.  The Consumer Financial Protection Bureau, as well as the other regulatory agencies, will conduct transaction testing prior to starting a HMDA review to ensure the data is correct.  If 10 percent or more of the HMDA LAR sample entries contain errors for a reporter with fewer than 100,000 entries the financial institution may be required to correct and resubmit the HMDA data; for reporters with greater than 100,000 entries correction and resubmission may be required with four percent or more of the sample entries containing errors.

To avoid having to resubmit, make sure you have the HMDA LAR correct at time of submission and the best time to start that HMDA scrub is now for the 2021 HMDA data.  Regulatory Solutions can assist you with this by scrubbing your data on a monthly or quarterly basis and providing you with an exception report detailing each data point needing correction.  Contact us today at 205-736-7717 to discuss how we can help you Get it Right.

Now that you have filed your 2020 HMDA LAR, it is time to get started scrubbing your 2021 HMDA Data.  Let Regulatory Solutions help by scrubbing your 2021 HMDA LAR to source data using our proprietary HMDA Software.  The data from a financial institution’s HMDA LAR is used to help determine if lenders are servicing the housing needs of its communities and provides public officials information to develop and allocate housing and community development investments – so it is important that you Get It Right!  Contact us today to begin your 2021 HMDA LAR Data Scrub.