On October 17th, the FDIC, FRB, and OCC released what they will consider to be “key” HMDA data fields per the changes effective January 1, 2018. These fields are considered to be the most important to ensuring HMDA data is accurate and useful for meaningful analysis.
The FFIEC HMDA Examiner Transaction Testing Guidelines lays out testing procedures to be used by the Agencies, but does not establish any key fields. Obviously, by increasing HMDA to 110 data fields, there were plenty to choose from and the Agencies have designated 37 key fields. These were selected based not only on reporting requirements and the need for accurate data, but also on exam efficiency and previous exam experiences.
The FDIC, FRB, and OCC will focus their primary attention on these key fields when doing transaction testing, although additional data fields may also be reviewed.