I don’t know about you, but it is starting to feel a little bit like a NASA control room around here. Each day that ticks by represents another second being counted down toward the launch of HMDA. Each of these seconds inducing another bead of sweat. Hold on while I step away to grab a towel…….
But hey, we recently received a little help from the folks at the CFPB so we can’t complain too much, right? Nothing like being at the eleventh hour, but at this point we’ll take what we can get. So let’s take a look back at what those changes were.
The biggest difference maker was the increase to the open-end reporting threshold. The CFPB finalized the amendment to increase the number from 100 to 500. There are probably a few lucky folks out there that went from preparing to be first time HMDA reporters, back to the penthouse with the other non-reporters. So this means if you originated 500 or more open-end covered transactions in 2016 and 2017, you will report the new data on open-end covered transactions in 2018. The one caveat here is that this is a “temporary” increase to the threshold. The CFPB states that they will re-evaluate after two years to see if 500 is the right number, or if they want to move it back to the 100 figure. So enjoy the penthouse while you still can.
Our second form of relief came with the announcement of the updated FFIEC HMDA Examiner Transaction Testing Guidelines. These are the guidelines you should be following (because your examiners are) as you self-test your own data for accuracy. Yes, you should be self-testing your own data for accuracy. Here is how the CFPB and FFIEC summarized the changes:
In light of the new data fields that will be required beginning in 2018, the Guidelines:
- Eliminate the file error resubmission threshold under which a financial institution would be directed to correct and resubmit its entire Loan Application Register (LAR) if the total number of sample files with one or more errors equaled or exceeded a certain threshold
- Establish, for the purpose of counting errors toward the field error resubmission threshold, allowable tolerances for certain data fields
- Provide a more lenient 10 percent field error resubmission threshold for financial institutions with LAR counts of 100 or less, many of which are community banks and credit unions
As I said before, at this point we will take what we can get. It is at least one less towel that I will have to go through.