The OCC, FDIC and CFPB have announced that they don’t intend to require HMDA Data resubmission or assess civil money penalties for 2018 HMDA data (reported in 2019), unless errors are material. We have not seen a similar announcement from the FRB. The CFPB has also stated they will reconsider institutional and transactional coverage tests and certain data requirements.
So, while not a total “get out of jail free card”, HMDA banks are apparently being offered some relief as we navigate through the new requirements. As long as you’ve prepared appropriately, you should have a comfort level that any fine-tuning to your procedures and processes can be done without the risk of resubmission or civil money penalties. Exams of the 2018 data “will be diagnostic to help institutions identify compliance weaknesses and will credit good faith compliance efforts.” That should be a relief!
There may be other changes coming to the Rule, as the Bureau intends to look at the lending activity that makes institutions subject to HMDA, as well as the types of transactions and data required to be reported. Of course, we’ll keep you updated with where that goes, but for now, it’s almost time to flip the switch on the 2018 Rule changes!
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!