The Bureau of Consumer Financial Protection (the BCFP, formerly known as the CFPB, but I digress) has released a new Filing Instruction Guide (FIG) to help you file your HMDA-LAR data. That’s a lot of acronyms in one sentence! J But this new FIG is not for your 2018 data! It’s for your 2019 data. The last FIG for 2018 data was dated September 2018. The new FIG is dated October 2018, but again, only for your 2019 data. This seems a little confusing, so allow me to explain.
If you don’t already know, the FIG is the way the BCFP announces technical changes to HMDA. For instance, if there are no origination fees, do you enter “0”, leave it blank, report “NA” or is there a code to represent this? The answer can only be found in the FIG and there are inconsistencies between various data fields. For example, if there are no origination fees, you enter “0”, but if there are no discount points, you leave it blank. The answers to these questions can vary from FIG to FIG, so you have to check the latest edition (or the last one relevant to the year you are reporting) carefully. You can check out all the FIGs that have been released (as well as other HMDA resources) here.
We’re almost a full ten months in with collecting the expanded HMDA data, which means your first HMDA-LAR submission isn’t that far off. How are you auditing your HMDA data to ensure it’s correct? If you need some guidance, tips, trick and or problem areas to focus your efforts, be sure to check out our Auditing HMDA webinar on October 31st!