While we haven’t quite yet turned the calendar to 2021, it won’t be long and we want you to be prepared.
For HMDA filers, the CFPB has released its 2021 Filing Instructions Guide, a 2021 Guide for Quarterly Filers, and a 2021 Reference Chart. As a result, we’ve updated our HMDA Data Reporting Guide to Version 3.3.
For large filers, here are a couple of things to be aware of:
- A code was added under the Automated Underwriting System (AUS) data field for “Internal Proprietary System”.
- When reporting NMLS #’s, do not include zeros that are not part of the NMLSR ID (e.g., if the NMLSR ID is 64573, it should be entered as 64573, not 00064573). There apparently have been a number of errors in connection with this field.
There will be also be some new, clarified and revised edits for 2021. These include edits to help ensure proper use of “1111” as an “Exempt” code and to help ensure the NMLSR ID is valid and not entered as a zero.
Even as we look to 2021 HMDA reporting requirements, the end of 2020 hasn’t necessarily been quiet when it comes to HMDA. Just over a month ago, the CFPB announced a civil money penalty of $200,000 for HMDA errors. As with most consent orders, there is a list of requirements that must be adhered to, including granting the CFPB permission to interview employees, which doesn’t sound like much fun!
The CFPB determined the errors were caused…by a lack of appropriate staff, insufficient staff training, and ineffective quality control and …directly related to weaknesses in Respondent’s compliance-management system (CMS), especially in the areas of Board and management oversight, monitoring, and policies and procedures.
This consent order actually takes us back to a 2017 resubmission which reflected “significant errors” above applicable thresholds, and, in turn “broad CMS failures”. Further, the errors were found to be intentional rather than “bona fide”. It’s no surprise that the CFPB found the institution had inadequate procedures and controls, due not only to the errors across multiple data fields, but the inability to identify and correct them.
HMDA reporting is not easy and we have a wide variety of training available to fit your needs. Visit our Store to find just what you’re looking for or give us a call! Make sure you’re as prepared (as possible) to take on whatever compliance challenges come your way in 2021!