Regulatory Alerts2017-12-21
Expectations for Supervised Institutions Regarding Amended Regulation C
The Federal Reserve Board issued guidance to all supervised institutions regarding compliance with the Consumer Financial Protection Bureau's amendments to Regulation C. For HMDA data collected in 2018 and reported in 2019, the Board will not require resubmission or assess penalties for non-material errors, treating examinations as diagnostic to support good faith compliance efforts. Institutions must continue to submit 2017 data in 2018 in accordance with the existing Regulation C requirements.
ERIC S. BELSKY DIRECTOR DIVISION OF CONSUMER AND COMMUNITY AFFAIRS CA 17-4 December 21, 2017 TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS: 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. SUBJECT: Expectations for Supervised Institutions Regarding Amended Regulation C This letter provides guidance on the Federal Reserve Board’s supervisory expectations in connection with early examinations of Board-supervised institutions for compliance with the Consumer Financial Protection Bureau’s (Bureau) October 15, 2015 and August 24, 2017 amendments to Regulation C (Home Mortgage Disclosure), which implements the Home Mortgage Disclosure Act (HMDA).1 . Recognizing the impending January 1, 2018 effective date of the Bureau’s amendments to Regulation C and the significant systems and operational challenges needed to adjust to the revised regulation, for HMDA data collected in 2018 and reported in 2019 the Federal Reserve does not intend to require data resubmission unless data errors are material. Furthermore, the Federal Reserve does not intend to assess penalties with respect to errors in data collected in 2018 and reported in 2019. Collection and submission of the 2018 HMDA data will provide financial institutions an opportunity to identify any gaps in their implementation of amended Regulation C and make improvements in their HMDA compliance management systems for future years. Any examinations of 2018 HMDA data will be diagnostic to help institutions identify compliance weaknesses and will credit good faith compliance efforts. For data collected in 2017, financial institutions will submit their reports in 2018 in accordance with the current Regulation C using the Bureau’s HMDA Platform. 1 See 80 FR 66127 (October 28, 2015); 82 FR 43088 (September 13, 2017).
Page 2 of 2 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.2
Sincerely, 2 See http://www.federalreserve.gov/apps/contactus/feedback.aspx.