Agencies release ‘key fields’ for collecting 2018 HMDA data

Key data fields to be used in collecting information for evaluating financial institution compliance with Home Mortgage Disclosure Act (HMDA) requirements were released Tuesday by federal banking agencies.

The key data fields are most important in ensuring the integrity of analyses of HMDA data, the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) said in a release. Working together, the agencies said, their development of joint key fields “promote efficiency, coordination, and consistency.”

The FDIC said in a release that compliance examination staff will prioritize the Designated Key HMDA Data Fields in reviewing data that is collected by financial institutions in or after 2018 pursuant to the HMDA Amendments. The list of 110 data fields was included in Financial Institution Letter (FIL) 51-2017.

The three banking agencies pointed out that HMDA requires certain financial institutions to collect, record, and report information about their mortgage lending activity; amendments to Regulation C (HMDA amendments) establish the data to be collected. Traditionally, the agencies said, they have identified and focused examination-related testing of HMDA data on certain agency-designated “key fields.”

Acting Comptroller of the Currency Keith Noreika released a statement about the “key fields” release,   recounting that, in conversations with OCC examiners and community banks across the country, he has heard how HMDA data reporting creates “unnecessary burden … when they are required to resubmit their entire HMDA reports simply because of a few minor errors.”

“It has become clear to me that examiners need discretion to exercise judgement to ensure corrections of errors and proper reporting of HMDA data, without imposing the needless burden involved in a full resubmission,” he said. “The OCC’s bulletin makes clear to OCC examiners that they have the discretion and should exercise judgment in their supervisory actions to ensure the accurate collection of HMDA data without requiring burdensome resubmissions.”


FDIC Releases Interagency Designated Key HMDA Data Fields List

OCC Bulletin 2017-41, “Home Mortgage Disclosure Act: Interagency Key Fields”