The CFPB announced two HMDA related resources this week.
First, the Bureau released additional 2017 HMDA data and the good news is you don’t have to do much. Prior to 2018, when the regulators released the HMDA data, you had to put a copy of it in your CRA Public File. Starting in 2018, you no longer had to print out your data and put it in the CRA Public File since your lobby notice informs people how to get this information directly from the CFPB. Unfortunately, the Community Reinvestment Act (Regulation BB) still requires you to put a notice in your CRA Public File. The notice basically says the same thing as your HMDA lobby notice which seems duplicative, doesn’t it? You can find the specifics here: §228.43(b)(2) for FRB regulated institutions, §345.43(b)(2) for FDIC regulated institutions and §25.43(b)(2) for OCC regulated institutions. Regardless of your regulator, they all say, “The bank shall place the written notice(s) in the public file within three business days after receiving notification . . .”. In other words, you should have done this already. If you haven’t, do it right away.
Second, the Bureau announced the availability of the File Format Verification Tool (FFVT) for HMDA data collected in 2018. The FFVT is a resource for testing whether the HMDA files meet the formatting requirements. The CFPB states:
The FFVT was developed with no login functions and does not log identifying information about FFVT users or the files they upload. The FFVT simply allows HMDA filers to test the formatting of their files. Thus, no Federal agency will receive or be able to view the files you test using it.
We’re still waiting to receive more guidance on the regulatory relief for small filers. When we do, we’ll pass it on to you. If you have any questions about HMDA, be sure to check out our numerous On-Demand training webinars or contact us. We’re here to help!