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.
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!