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!