FDIC: FFIEC Revises A Guide to HMDA Reporting: Getting It Right!

The Federal Financial Institutions Examination Council (FFIEC) has revised A Guide to HMDA Reporting: Getting It Right! to reflect the October 2015 Home Mortgage Disclosure Act (HMDA) final rule, as amended in 2017. This compliance resource should help financial institutions better understand the final rule’s requirements, including the data collection and reporting provisions.

Statement of Applicability to Institutions with Total Assets under $1 Billion: This Financial Institution Letter applies to all FDIC-supervised institutions subject to HMDA and Regulation C. A HMDA exemption applies to institutions with assets at or below a threshold specified in Regulation C.

Highlights:

HMDA, which is implemented by Regulation C, requires certain financial institutions to collect, report, and disclose information about their mortgage lending activity.

• A Guide to HMDA Reporting: Getting It Right! provides a summary of key HMDA provisions, including information about HMDA’s data collection, reporting, and disclosure requirements, and the purpose of these requirements.
• Getting It Right can serve as a useful compliance resource for supervised financial institutions.
• The FFIEC has revised Getting It Right to reflect revisions to Regulation C included in the October 2015 HMDA Final Rule, as amended in 2017.
• On December 21, 2017, the FDIC issued a “Statement on Institutions’ Good Faith Compliance Efforts,” which clarifies that, in recognition of the significant systems and operational challenges required to implement the final rule, FDIC examinations of 2018 HMDA data will be diagnostic (i.e., to help institutions identify compliance weaknesses) and will credit good faith compliance efforts.
• In addition, the FDIC has developed a new method for institutions and their consumer compliance personnel to opt in to receive alerts when the FDIC’s Compliance Examination Manual (CEM) is updated or revised. To be notified when the CEM is updated, register on the FDIC’s Email Updates webpage at https://service.govdelivery.com/accounts/USFDIC/subscriber/new.