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!
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.