By Gina Ellis, CRCM
As we noted in an earlier blog, regulatory agencies announced the issuance of Home Mortgage Disclosure Act (HMDA) Examiner Transaction Testing Guidelines to support the evaluation of financial institutions’ compliance with HMDA’s new requirements beginning January 1, 2018. Those guidelines describe testing procedures to be used by the regulatory agencies to validate the accuracy of HMDA data collected during 2018 and reported in 2019.
The regulatory agencies have now issued designated key data fields that are considered to be the most important to ensure the integrity of analyses of the overall HMDA data. All 110 data fields were included in the list released, with the designated key fields, 37 of the 110, shown in italicized bold text. That list can be found here: https://www.fdic.gov/news/news/financial/2017/fil17051a.pdf
While your training efforts will certainly want to focus on the designated key data fields, you cannot ignore the remaining fields. The information released by the regulatory agencies indicates examination staff may determine, in certain circumstances, that it is necessary to review additional HMDA data fields as appropriate. Who knows what that might mean for financial institutions, but we recommend you begin training and implementing review procedures now to avoid errors in key data fields and additional scrutiny.
Our compliance consultants are gearing up for the HMDA changes and are here to assist you with additional audits, monitoring and guidance. If your institution needs help, contact us at www.americanbanksystems.com or call (405) 607-7000.