The Office of the Comptroller of the Currency (OCC) today issued a bulletin to inform national banks, federal savings associations, and insured federal branches and agencies of foreign banks about key fields examiners will typically use to validate the accuracy and reliability of home mortgage loan data collected beginning in 2018 pursuant to the Home Mortgage Disclosure Act (HMDA) rule issued October 15, 2015.
The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the OCC issued similar guidance designating the same key fields for these purposes. In doing so, Acting Comptroller of the Currency Keith A. Noreika issued the following statement:
I commend the hard work of the staffs of the OCC and the other federal banking agencies. The action the agencies take today will support the efficient and effective evaluation of financial institutions’ compliance with the requirements of HMDA.
In my conversations with OCC examiners and community banks across the country, I have heard how HMDA data reporting can create unnecessary burden, especially for small community banks, when they are required to resubmit their entire HMDA reports simply because of a few minor errors. It has become clear to me that examiners need discretion to exercise judgement to ensure corrections of errors and proper reporting of HMDA data, without imposing the needless burden involved in a full resubmission. The OCC’s bulletin makes clear to OCC examiners that they have the discretion and should exercise judgment in their supervisory actions to ensure the accurate collection of HMDA data without requiring burdensome resubmissions.