The Board of Governors of the Federal Reserve System issued Consumer Affairs Letter CA 18-2 to distribute a revised guide for Home Mortgage Disclosure Act (HMDA) reporting. This guidance supports financial institutions in complying with Regulation C amendments effective for data collected starting January 1, 2018, by clarifying changes to institutional coverage, transaction types, and data collection requirements. The letter applies to all Federal Reserve-supervised institutions and provides an easy-to-use summary of key provisions to assist with accurate reporting and disclosure.
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CA 18-2: Revised “A Guide to HMDA Reporting: Getting It Right!”
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D.C. 20551
DIVISION OF CONSUMER AND COMMUNITY AFFAIRS
CA 18-2
March 6, 2018
TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS:
SUBJECT:
Revised “A Guide to HMDA Reporting: Getting It Right!”
Applicability to Community Banking Organizations: This guidance applies to all institutions supervised by the Federal Reserve, including those with total consolidated assets of $10 billion or less.
The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council recently developed a revised version of "A Guide to HMDA Reporting: Getting It Right!" (Guide). The updated Guide is for use in connection with Home Mortgage Disclosure Act (HMDA) 1 data collected beginning on January 1, 2018 pursuant to the Consumer Financial Protection Bureau's (Bureau) October 15, 2015 and August 24, 2017 amendments to Regulation C (Home Mortgage Disclosure). 2
HMDA and Regulation C require certain depository institutions and for-profit non-depository institutions to collect, report, and disclose data about originations and purchases of mortgage loans as well as mortgage loan applications that do not result in originations. The Bureau's October 2015 and August 2017 final rules modified: (1) the types of institutions that are subject to Regulation C; (2) the types of transactions that are subject to Regulation C; (3) the types of data that institutions are required to collect, record, and report pursuant to Regulation C; and (4) the corresponding processes for reporting and disclosing HMDA data.
The updated Guide – which applies to HMDA data collected beginning on January 1, 2018 that is to be submitted by March 1, 2019 – is intended to assist financial institutions to comply with HMDA and Regulation C by providing helpful background information and an easy-to-use summary of key provisions, including regarding institutional coverage, transactional coverage, and data collection, reporting, and disclosure requirements.
If you have any questions, please contact Amal Patel, Senior Supervisory Consumer Financial Services Analyst, at (202) 912-7879, or Tim Robertson, Manager, at (202) 452-2565. In addition, questions may be sent via the Board's public website. 3
signed by Carol A. Evans Associate Director Division of Consumer and Community Affairs
Attachments:
Revised "A Guide to HMDA Reporting: Getting It Right!" (PDF)
Cross References:
CA 17-4 "Expectations for Supervised Institutions Regarding Amended Regulation C" (December 21, 2017)
CA 17-3 "Designated Home Mortgage Disclosure Act Key Data Fields" (October 17, 2017)
CA 17-2 "Revised Interagency Home Mortgage Disclosure Act Sampling, Verification, and Resubmission Procedures" (August 22, 2017)
Notes:
12 U.S.C. 2801 et seq . Return to text
See 80 FR 66127 (October 28, 2015); 82 FR 43088 (September 13, 2017). Return to text
See http://www.federalreserve.gov/apps/contactus/feedback.aspx . Return to text
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Last Update:
March 06, 2018