Helping financial institutions “better understand” revisions made last year to federal mortgage disclosure requirements – including data collection and reporting provisions – is the aim of a new guide issued late last month, the federal deposit insurer is advising banks and savings associations.
In Financial Institutions Letter (FIL) 10-2018 issued Monday, the Federal Deposit Insurance Corp. (FDIC) said a revised “Guide to HMDA Reporting: Getting It Right!” issued in February by the Federal Financial Institutions Examination Council (FFIEC) provides a summary of key Home Mortgage Disclosure Act (HMDA) provisions. The guide, FDIC said, also includes information about HMDA’s data collection, reporting and disclosure requirements – including the purpose of the requirements.
“Getting It Right can serve as a useful compliance resource for supervised financial institutions,” FDIC said in its letter, distributed to insured financial institutions. “The FFIEC has revised Getting It Right to reflect revisions to Regulation C included in the October 2015 HMDA Final Rule, as amended in 2017.”
The deposit insurer pointed out that in December it issued a “Statement on Institutions’ Good Faith Compliance Efforts.” That statement, the agency said, clarifies that “in recognition of the significant systems and operational challenges required to implement the final rule,” FDIC examinations of 2018 HMDA data will be diagnostic (that is, focused on helping institutions identify compliance weaknesses) and “will credit good faith compliance efforts.”
Also, FDIC said in the FIL that it has developed a new method for institutions and their consumer compliance personnel to opt in to receive alerts when the FDIC’s Compliance Examination Manual (CEM) is updated or revised (see link below).