Regulatory Compliance
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Slow and Steady is the Pace

We are slowly starting to receive more information from the CFPB when it comes to guidance on how HMDA reporting will look as we prepare for the changeover. They recently published a “HMDA Loan Scenarios” guide that walks through a few examples of how the reporting should look now that HMDA submissions will be sent directly to them. One of the key technical pieces with this reporting is the “Pipe Delimited” file format that is required. If you are like me and had no clue what that was before these new requirements, the CFPB provided some pictures for us within the loan scenario guide. Hopefully you have a LOS or HMDA software vendor that can help you out with this. If not, the CFPB has also been oh so helpful by providing a conversion tool on their implementation website.

There is still no word on when the submission site will be up and running. Rumor has it that they will be ready by the end of the third quarter. If you are a technical wiz unlike myself and have a little free time on your hands, you can go out to to see the algorithms and methodologies that are being used to validate a HMDA file. This was the CFPB’s attempt at being transparent throughout the process.

Remember that these changes are just around the corner, and that data collected this year will be submitted to the CFPB next year. That means now is a good time to start taking a look at this info. I highly suggest that you start playing around with your current data to get an idea of how you will properly format it before submitting. You do not want to spend the first three months of next year scrambling on 2017 HMDA while you are implementing 2018 HMDA.

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