Compliance Alliance Q&A 10-2-17

Question:

Which loans will the new HMDA 2018 data point requirements apply?

Answer:

The HMDA amendments for 2018 require reporting of most of the new and revised data points for loans closing in 2018, including those loans applied for in 2017.  The exception, however, is for data on race, ethnicity, and sex.  The CFPB clarified in guidance that banks will not need to provide the newly revised data points for these three categories for applications from 2017 that close in 2018 - compliance with the regulations on data points from 2017 will still suffice.  However, any applications applied for on or after January 1, 2018, will require use of the amended guidelines on gathering this data.

The CFPB has a chart on the data points, including those which were modified and added, at:

http://files.consumerfinance.gov/f/201510_cfpb_hmda-summary-of-reportable-data.pdf

Regarding loans closed in 2017 and reported on in 2018, the 2017 rules apply.  

 

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Contact Diane Harman for more information. 

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