Death, taxes and HMDA reporting requirements — as the government shutdown grinds on, few things remain as constant as these three absolutes.
But a few things have changed since you last submitted your mortgage data for the Home Mortgage Disclosure Act (HMDA) to the Consumer Financial Protection Bureau. Time will tell if these changes have made things better, worse or just more complicated, but credit unions subject to the requirements should pay close attention.
We’ve already discussed requirement changes for 2018 data as compared to years past. In many cases the new data fields are designed to catch errors in the making, and new processes have automated the agency’s error response capabilities. PolicyWorks is happy to help you with a review of and recommendations for filling out the electronic forms.
If you are a credit union that falls within the partial exemption that was created with the passing of the Economic Growth, Regulatory Relief, and Consumer Protection Act, make sure you pay attention to how you are filling out your Loan Application Register. Details on those changes can be found here.
The final-final due date for correctly completed submissions is still March 1, but credit unions required to report their mortgage data can start submitting that information now. Last year the CFPB has moved to online-only data submissions, a process outlined in a rather snappy 1:21 video infographic.
The HMDA platform will immediately review all data submissions, and forms with errors or omissions will be spit back to the sender for correction and completion. Once completed, the forms must be certified by the credit union and submitted by March 1.
Other changes made this year include an increase in the asset size of institutions required to report their HMDA data to include those with $46 million or more in assets as of December 31, 2018, up from $45 million last year. Credit unions with assets less than $46 million need not collect HMDA information for 2019.