Instructions for filing Home Mortgage Disclosure Act (HMDA) data collected in 2019 are available now via a website housing HMDA guidance applicable to all federally supervised mortgage lenders.
HMDA, implemented by the Bureau of Consumer Financial Protection (BCFP, formerly known as CFPB) through Regulation C, was revised under the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA, S. 2155) to provide some insured depository institutions limited exemptions from the HMDA requirements. The bureau published an interpretive ruling Aug. 31 to explain the changes in requirements and procedures, updated its 2018 HMDA Filing Instructions Guide (FIG), and said it expected to initiate a notice-and-comment rulemaking later to incorporate the changes into Reg C “and further implement” EGRRCPA. (That additional rulemaking has yet to be published.)
The 2018 FIG gives technical guidance for reporting data collected in 2018 and reportable in 2019 via the loan/application register (LAR). The recent 2019 update to the guide will apply to data collected in 2019 and reportable in 2020.
The 2019 FIG is available via the FFIEC HMDA Website, a site maintained by the umbrella Federal Financial Institutions Examination Council. The council includes representatives from the federal bank and credit union regulators, BCFP, and the State Liaison Committee (which itself has five representatives of state supervisory agencies).