Back in October, we alerted you to the fact that the CFPB had released a new Filing Instructions Guide (FIG) for HMDA data collected in 2019. As a result, we’ve updated our HMDA Data Guide. Version 3.0 is available now in our free lending tools. Please note that these additions will not impact the data you collected in 2018. Rather, they apply to HMDA data collected in 2019, that will be submitted in 2020.
So, what changed?
- Codes 18 – 24 were added to the list of options when reporting the results from an Automated Underwriting System (AUS):
20. Accept/Unable to Determine
21. Refer with Caution/Eligible
22. Refer with Caution/Ineligible
23. Refer/Unable to Determine
24. Refer with Caution/Unable to Determine
The FIG does tell us that added codes 18 and 19 correspond to results frequently returned by FHA Total Scorecard. Any of the added codes may also commonly be reported by the Guaranteed Underwriting System (GUS). The FIG also clarifies that while it specifies certain codes as being commonly seen with certain underwriting systems, you should ultimately report the result you receive. For example, the FIG says that the GUS commonly gives results that correspond to codes 3, 4, 10, 15, 18 – 24. However, that doesn’t mean that those are the only results that can be reported for that system.
- The names of the Credit Scoring models were also revised for Codes #3 and #4 (e.g. FICO Risk Score Classic 04 is now TransUnion FICO Risk Score Classic 04).
While the changes aren’t necessarily major changes, it’s still important you are aware of them. Let’s be honest, there are few regulations that cause more headaches and confusion than HMDA! If you’re looking for HMDA training, visit our store to register for HMDA: Are You Ready to Submit Your 2018 Data? coming on January 10th and HMDA Transaction Coverage on January 22nd.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!