Added on February 3, 2016
The official 2018 HMDA changes document was finalized in October 2015. That document had many of the ideas that were finalized but it did not contain the technical details that we need as a software provider to implement the changes. Without the "official" enumerations for all of the new fields, and more specifically on the re-used but updated fields, it is hard for us to complete specifications for our programmers.We are currently in communication with the CFPB and are trying to get clarifications on the questions we have.
Once we have these answers we are planning to implement them into Comply for the 2018 reporting years and forward. The Application screens will stay the same for all years prior to 2018 then 2018 will display the new fields and the new enumerations.We will be activating the 2017 and 2018 reporting years with the release of Comply 2016 near the end of this year and at that point you should be able to begin importing test data for the 2018 reporting year.Again, all of this is contingent on the CFPB releasing the full technical specifications which we anticipate they will.
That is where we are at this time.
The CFPB has finally released preliminary information on the final HMDA changes that are set to take effect beginning with data collection January 1, 2018, to be submitted March 1, 2019. As usual, they did not hold back on their use of verbiage given the fact that the document is 797 pages and is still only the tip of the iceberg. This document does not contain new field enumerations, edits or file submission specifications. What it does contain (again, a lot of information) is the fields that will be collected, both new and existing fields that will contain new values, and timetables for implementing different stages.
RATA is firmly aware of what these changes entail and will be working vigorously to implement the changes from our side in a way that lets you continue to collect data as usual through the end of 2017 and then seamlessly migrate to the new data formats for 2018. We are still internally working through the logistics of implementing the changes and will post updates along the way to explain what we are doing.
Implementing these changes will be a challenge for institutions of all sizes but, RATA is here to help you in whatever way we can to submit your data accurately through the transitions.
More to come…