Every year, thousands of financial institutions rush to meet the March 1 HMDA filing deadline—and every year, edit check errors slow them down. These validation failures can range from simple data entry mistakes to complex logic conflicts that require careful analysis to resolve. After helping institutions file HMDA data for nearly four decades, we've seen the same errors appear again and again. Here's how to identify and fix the 10 most common HMDA edit check errors before they delay your submission. Understanding HMDA Edit Check Types Before diving into specific errors, it's important to understand the three types of HMDA edit checks: Syntax Edits: Verify data format and structure. These must be corrected before submission. Validity Edits: Confirm values fall within acceptable…
The March 2, 2026 deadline for submitting your 2025 HMDA data is approaching. (Note: The deadline is March 2nd this year because March 1st falls on a Sunday.) Whether this is your first filing or your thirtieth, a structured preparation process helps ensure accurate, timely submission and avoids last-minute scrambling. This checklist covers the essential steps compliance officers should complete before submitting to the FFIEC's HMDA Platform. Key Dates to Remember Before diving into the checklist, mark these critical dates: January 1, 2026: Begin final data review and validation February 15, 2026: Recommended internal submission deadline (allows buffer for corrections) March 2, 2026: CFPB filing deadline (no extensions granted) — moved from March 1 because it falls on a Sunday…
Why Redlining Risk Should Continue to Be a Focus During the Next Administration In the lead-up to the change in administration, the CFPB and DOJ have settled redlining claims against non-depository mortgage companies. On January 17, 2025, the CFPB settled redlining claims against a non-depository mortgage company, Draper & Kramer Mortgage Corporation, based on activity from 2019 to 2021 in the Chicago-Naperville-Elgin and Boston-Cambridge-Newton metropolitan statistical areas (Chicago and Boston MSAs, respectively). The CFPB's settlement includes a $1.5 million civil money penalty and a prohibition against the company from engaging in any residential mortgage lending activities for five years. The week prior, on January 7, 2025, the Department of Justice (DOJ)…
Settlement is the first government resolution involving illegal discrimination by a nonbank mortgage lender Washington, D.C. – Today, the Consumer Financial Protection Bureau (CFPB) and U.S. Department of Justice (DOJ) took action to end Trident Mortgage Company's intentional discrimination against families living in majority-minority neighborhoods in the greater Philadelphia area. The CFPB and DOJ allege Trident redlined majority-minority neighborhoods through its marketing, sales, and hiring actions. Specifically, Trident's actions discouraged prospective applicants from applying for mortgage and refinance loans in the greater Philadelphia area's majority-minority neighborhoods. If entered by the court, the settlement, among other things, would require Trident to pay a $4 million…
Trustmark to Pay $5 Million Penalty and $3.85 Million to Increase Mortgage Credit Access in Memphis Neighborhoods Impacted by Redlining WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) and U.S. Department of Justice (DOJ), in cooperation with the Office of the Comptroller of the Currency (OCC), took action today to put an end to alleged redlining by Trustmark National Bank. The CFPB and DOJ allege that Trustmark discriminated against Black and Hispanic neighborhoods by deliberately not marketing, offering, or originating home loans to consumers in majority-Black and Hispanic neighborhoods in the Memphis metropolitan area. The CFPB and DOJ also allege that Trustmark discouraged consumers residing in or seeking credit for properties located in these…
WASHINGTON, D.C. — Today, the Consumer Financial Protection Bureau (Bureau) settled with Washington Federal Bank, N.A., a federally insured national bank, to address the Bureau's finding that it reported inaccurate Home Mortgage Disclosure Act (HMDA) data about its mortgage transactions for 2016 and 2017. Inaccurate HMDA data can make it difficult for the public and regulators to discover and stop discrimination in home mortgage lending or for public officials and lenders to tell whether a community's credit needs are being met. The settlement requires Washington Federal to pay a $200,000 civil money penalty and develop and implement an effective compliance-management system to prevent future violations. The Bureau found that Washington Federal, headquartered in Seattle,…
December 22, 2018 It's been a major issue for our industry. In fact, one of our feature stories for the December magazine, written by our Managing Editor Sarah Wheeler, details the new risks HMDA reporting represents for lenders. And earlier this year HousingWire warned lenders that if they think compliance is hard now, just wait until the new HMDA regulations kick in. Most of the 2015 updates to HMDA take effect in January 2018. However, now, both the Office of the Comptroller of the Currency and the Consumer Financial Protection Bureau — both now led by Trump-administration leaders (more, below) — announced they will not be assessing penalties on HMDA data collected in 2018 and reported in 2019. What's more, the CFPB also intends to open a rulemaking to reconsider…
December 21, 2018 HMDA, which was originally enacted in 1975, requires many lenders to report information with respect to applications they receive for certain types of mortgage loans and certain loans that they purchase. The Dodd-Frank Wall Street Reform and Consumer Protection Act directed the Bureau to expand the data collected and reported under HMDA to include additional information regarding, for example, mortgage loan underwriting and pricing, and authorized the Bureau to require other data. To that end, the Bureau issued a rule in 2015 that requires financial institutions to collect and report additional mortgage information beginning on January 1, 2018. In August 2017, the Bureau issued a final rule making technical corrections, clarifying certain reporting…
The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency today announced the availability of the 2017 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration under the community development definition. Distressed nonmetropolitan middle-income geographies and underserved nonmetropolitan middle-income geographies are designated by the agencies in accordance with their CRA regulations. The criteria for designating these areas are available on the Federal Financial Institutions Examination Council (FFIEC) website (http://www.ffiec.gov/cra). The designations continue…
Today we released a proposal to amend Regulation C to provide certain clarifications that would help companies comply with their data reporting requirements. Regulation C implements the Home Mortgage Disclosure Act (HMDA). The Home Mortgage Disclosure Act (HMDA) requires many financial institutions to maintain, report, and publicly disclose information about mortgages. HMDA was originally enacted by Congress in 1975. These public data are important because they help show whether lenders are serving the housing needs of their communities; they give public officials information that helps them make decisions and policies; and they shed light on lending patterns that could be discriminatory. In October 2015, the Bureau issued the 2015 HMDA Final Rule, after a multi-year policy…
Proposal Would Clarify Requirements and Help Companies Comply WASHINGTON, D.C. – The Consumer Financial Protection Bureau (CFPB) today issued a proposal to facilitate compliance with the 2015 updates to the Home Mortgage Disclosure Act (HMDA) rule. The changes proposed today would help financial institutions comply with the 2015 HMDA Final Rule by clarifying the information they are required to collect and report about their mortgage lending. "The Home Mortgage Disclosure Act shines a much-needed spotlight on the mortgage market, which is the largest consumer financial market in the world," said CFPB Director Richard Cordray. "Today's proposal reflects the Bureau's ongoing and substantive engagement with stakeholders in the marketplace, and will help industry meet its new reporting…
Proposed Rule Would Also Aid in Adoption of New Forms WASHINGTON, D.C. – The Consumer Financial Protection Bureau (CFPB) today released a proposal to amend Equal Credit Opportunity Act regulations to provide additional flexibility for mortgage lenders in the collection of consumer ethnicity and race information. The CFPB believes the proposed amendments will provide greater clarity to lenders regarding their obligations under the law, while promoting compliance with rules intended to ensure consumers are treated fairly. "This law is a key part of the government's commitment to root out discrimination," said CFPB Director Richard Cordray. "This proposal will help industry comply with the law and help protect consumers against illegal discrimination." The Equal Credit…
Bureau's $1.75 Million Civil Penalty for Persistent and Substantial Reporting Errors is the CFPB's Largest Penalty to Date for HMDA Violations WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) today ordered Nationstar Mortgage LLC to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (HMDA) by consistently failing to report accurate data about mortgage transactions for 2012 through 2014. Today's action is the largest HMDA civil penalty imposed by the Bureau to date, which stems from Nationstar's market size, the substantial magnitude of its errors, and its history of previous violations. In fact, Nationstar had been on notice since 2011 of HMDA compliance problems. In addition to paying the civil penalty, Nationstar must take the…
The federal bank regulatory agencies today announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. The annual adjustments are required by the CRA rules. Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification. Those meeting the small and intermediate small institution asset-size thresholds are not subject to the reporting requirements applicable to large banks and savings associations unless they choose to be evaluated as a large institution. Annual adjustments to these asset-size thresholds are based on the change in the average of the…
CFPB Puts 44 Mortgage Lenders and Brokers on Notice That They May Be Required to Report Mortgage Data WASHINGTON, D.C. – Today the Consumer Financial Protection Bureau (CFPB) is issuing warning letters to 44 mortgage lenders and mortgage brokers. The Bureau has information that appears to show they may be required to collect, record, and report data about their housing-related lending activity, and that they may be in violation of those requirements. "Financial institutions that fail to report mortgage information as required make it harder to identify and address discriminatory lending," said CFPB Director Richard Cordray. "No mortgage lender that is required to report their loan data can avoid this responsibility." The Home Mortgage Disclosure Act, which was originally enacted in…
The Federal Deposit Insurance Corporation (FDIC) Friday released the survey of branch office deposits as of June 30, 2016, for all FDIC-insured institutions. The Summary of Deposits (SOD) annually provides deposit totals for each of the more than 91,000 domestic offices operated by more than 6,000 FDIC-insured commercial and savings banks, savings associations, and U.S. branches of foreign banks. Users can locate offices in a particular geographic area and create custom market share reports for a geographic area such as state, county, and metropolitan area.The FDIC has expanded the market share reports to allow users to see market growth and market presence for specific institutions. Data dating back to 1994 can be downloaded for analysis. To receive annual updates of the SOD, go to the…
The Federal Financial Institutions Examination Council (FFIEC) today announced the availability of data on mortgage lending transactions at 6,913 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). Covered institutions include banks, savings associations, credit unions, and mortgage companies. The HMDA data made available today cover 2015 lending activity and include: applications, originations, purchases and sales of loans, denials, and other actions related to applications loan amount loan type (conventional, Federal Housing Administration (FHA), Veterans Administration (VA), Rural Housing Service (RHS) or Farm Service Agency (FSA)) purpose (home purchase, home improvement, or refinancing) property type (1-4 family, multifamily, or manufactured housing) owner…
he three federal banking agency members of the Federal Financial Institutions Examination Council (FFIEC) with Community Reinvestment Act (CRA) responsibilities — the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency — announced today the availability of data on small business, small farm, and community development lending reported by certain commercial banks and savings associations, pursuant to the CRA. An FFIEC disclosure statement on the reported 2015 CRA data, in electronic form, is available for each reporting commercial bank and savings association. The FFIEC also has prepared aggregate disclosure statements of small business and small farm lending for all of the metropolitan…
The federal bank regulatory agencies with responsibility for Community Reinvestment Act (CRA) rulemaking today published final revisions to "Interagency Questions and Answers Regarding Community Reinvestment". The Questions and Answers document provides additional guidance to financial institutions and the public on the agencies' CRA regulations. The new and revised guidance addresses questions raised by bankers, community organizations, and others regarding the agencies' CRA regulations in the following areas: Availability and effectiveness of retail banking services. Innovative or flexible lending practices. Community development-related issues, including: (i) economic development; (ii) community development loans and activities that revitalize or stabilize underserved nonmetropolitan…
The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation today announced the availability of the 2016 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration as community development. Distressed nonmetropolitan middle-income geographies and underserved nonmetropolitan middle-income geographies are designated by the agencies in accordance with their CRA regulations. The criteria for designating these areas are available on the Federal Financial Institutions Examination Council (FFIEC) website (http://www.ffiec.gov/cra). The designations continue to reflect local…
The Federal Reserve Board on Thursday announced the repeal of one regulation and a proposal to repeal a second in order to comply with statutory provisions that transferred certain consumer protection rulewriting authority to the Consumer Financial Protection Bureau (CFPB). The Board repealed its Regulation AA (Unfair or Deceptive Acts or Practices) as proposed in August 2014 and is inviting public comment on the proposed repeal of Regulation C (Home Mortgage Disclosure). The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) repealed the Board's authority to write rules that address unfair or deceptive acts or practices, which were contained in Regulation AA. Regulation AA included the Board's "credit practices rule," which prohibited banks from using certain…
The federal bank regulatory agencies, the Federal Reserve Bank of San Francisco, and the Community Development Financial Institutions Fund will host the 2016 National Interagency Community Reinvestment Conference in Los Angeles from February 8 to 10. This biennial conference offers participants from around the country the opportunity to learn about the Community Reinvestment Act (CRA) and to discuss best practices and emerging challenges in community development. The conference agenda includes keynote presentations by Thomas J. Curry, Comptroller of the Currency; Martin J. Gruenberg, Chairman of the Federal Deposit Insurance Corporation; Amias Gerety, Acting Assistant Secretary for Financial Institutions of the U.S. Department of Treasury; John C. Williams, President of the Federal…
The federal bank regulatory agencies, the Federal Reserve Bank of San Francisco, and the Community Development Financial Institutions Fund will host the 2016 National Interagency Community Reinvestment Conference in Los Angeles from February 8 to 10. This biennial conference offers participants from around the country the opportunity to learn about the Community Reinvestment Act (CRA) and to discuss best practices and emerging challenges in community development. The conference agenda includes keynote presentations by Thomas J. Curry, Comptroller of the Currency; Martin J. Gruenberg, Chairman of the Federal Deposit Insurance Corporation; Amias Gerety, Acting Assistant Secretary for Financial Institutions of the U.S. Department of Treasury; John C. Williams, President of the Federal…
The federal bank regulatory agencies today announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. The annual adjustments are required by the CRA rules. Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification. Those meeting the small and intermediate small institution asset-size thresholds are not subject to the reporting requirements applicable to large banks and savings associations. Annual adjustments to these asset-size thresholds are based on the change in the average of the Consumer Price Index for Urban Wage Earners and…
HMDA Asset-Size Exemption Threshold Unchanged at $44 Million; Higher-Priced Mortgage Loan Escrow Account Exemption Threshold Declines to $2.052 Billion WASHINGTON, D.C. – The Consumer Financial Protection Bureau (CFPB) today issued two final rules regarding annual threshold adjustments under the implementing regulations for the Home Mortgage Disclosure Act and the Truth in Lending Act. Home Mortgage Disclosure Act The CFPB issued a final rule regarding the asset-size exemption threshold for banks, savings associations, and credit unions under Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). HMDA requires that the CFPB adjust this threshold yearly by the annual percentage change in the average of Consumer Price Index for Urban Wage Earners and Clerical Workers…
WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB), Federal Reserve Board, and Office of the Comptroller of the Currency (OCC) today announced that the threshold for exempting loans from special appraisal requirements for higher-priced mortgage loans during 2016 will remain $25,500. The threshold amount will be effective January 1, 2016, and is the same threshold that applied in 2015–based on the annual percentage decrease in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) as of June 1, 2015. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 amended the Truth in Lending Act to add special appraisal requirements for higher-priced mortgage loans, including a requirement that creditors obtain a written appraisal…
Today the Consumer Financial Protection Bureau is updating the Home Mortgage Disclosure Act (HMDA) requirements with a new rule that will shine more light on lending practices in America's largest consumer financial market, the mortgage market. HMDA is a statute that provides the public and policymakers with information about the mortgage market and ensures market transparency. HMDA requires many financial institutions to collect, report, and disclose information about their mortgage activity. The original law was enacted by Congress 40 years ago to respond to concerns that some banks may be failing to serve their communities. Everyone in America deserves a fair shot at accessing the American Dream. The Home Mortgage Disclosure Act: Helps to show whether lenders are serving the housing…
Company to Pay $18 Million to Minority Auto Borrowers, $3 Million to Credit Card Customers
WASHINGTON, D.C. – Today the Consumer Financial Protection Bureau (CFPB) announced two separate actions against Fifth Third Bank, for discriminatory auto loan pricing and for illegal credit card practices. The joint CFPB and Department of Justice (DOJ) auto-lending enforcement action requires Fifth Third to change its pricing and compensation system to minimize the risks of discrimination, and to pay $18 million to harmed African-American and Hispanic borrowers. The CFPB's action against Fifth Third's deceptive marketing of credit card add-on products requires the bank to provide an estimated $3 million in relief to eligible harmed consumers and pay a $500,000 penalty.
Settlement Provides Over $27 Million to Ensure Equal Lending Services to Predominantly Black and Hispanic Communities
The Justice Department and Consumer Financial Protection Bureau (CFPB) filed a consent order today to resolve allegations that Hudson City Savings Bank (Hudson City) engaged in a pattern or practice of "redlining" predominantly Black and Hispanic neighborhoods in its residential mortgage lending practices. "Redlining" is the discriminatory practice by banks or other financial institutions to deny or avoid providing credit services to a consumer because of the racial demographics of the neighborhood in which the consumer lives. This resolution represents the Justice Department's largest residential mortgage redlining settlement in its history.
Today, the Federal Financial Institutions Examination Council (FFIEC) published the 2014 Home Mortgage Disclosure Act (HMDA) data showing that more people took out a mortgage to purchase a home in 2014 than in 2013 and that fewer people refinanced their mortgages. As part of our work to educate consumers to make informed financial decisions, we at the Consumer Financial Protection Bureau (CFPB) – along with the other members of the FFIEC – are committed to making HMDA data clear and available to you. The Home Mortgage Disclosure Act helps protect consumers by providing public data about the mortgage market. Consumers, public officials, community groups, researchers, developers, journalists, and mortgage professionals can use these data to better understand mortgage trends at a…
The Federal Financial Institutions Examination Council (FFIEC) today announced the availability of data on mortgage lending transactions at 7,062 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). Covered institutions include banks, savings associations, credit unions, and mortgage companies. The HMDA data made available today cover 2014 lending activity, and include applications, originations, purchases and sales of loans, denials, and other actions related to applications. The data released today also include disclosure statements for each financial institution, aggregate data for each metropolitan statistical area (MSA), nationwide summary statistics on lending patterns, and Loan/Application Registers (LARs) for each financial institution (LARs are modified…
The three federal banking agency members of the Federal Financial Institutions Examination Council (FFIEC) with Community Reinvestment Act (CRA) responsibilities—the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency—announced today the availability of data on small business, small farm, and community development lending reported by certain commercial banks and savings associations, pursuant to the CRA. An FFIEC disclosure statement on the reported 2014 CRA data, in electronic form, is available for each reporting commercial bank and savings association. The FFIEC also has prepared aggregate disclosure statements of small business and small farm lending for all of the metropolitan…
The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation today announced the availability of the 2015 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities will receive Community Reinvestment Act (CRA) consideration as community development. Distressed nonmetropolitan middle-income geographies and underserved nonmetropolitan middle-income geographies are designated by the agencies in accordance with their CRA regulations. The criteria for designating these areas are available on the Federal Financial Institutions Examination Council (FFIEC) website (http://www.ffiec.gov/cra). The designations continue to reflect local…
RPM CEO Erwin Robert Hirt to Pay Additional $1 Million Civil Penalty
WASHINGTON, D.C. – Today, the Consumer Financial Protection Bureau (CFPB) filed a complaint in federal district court against RPM Mortgage, Inc. and its CEO, Erwin Robert Hirt, for illegally paying bonuses and higher commissions to loan originators to incentivize them to steer consumers into costlier mortgages. The CFPB also filed a proposed order that, if entered by the court, would require RPM to pay $18 million in redress to consumers and a $1 million civil penalty, and would require Hirt to pay an additional $1 million civil penalty.
Settlement Provides $9 Million in Compensation to African-American and Hispanic Borrowers
The Justice Department and Consumer Financial Protection Bureau (Bureau) filed a consent order today to resolve allegations that Provident Funding Associates (Provident) engaged in a pattern or practice of discrimination that increased loan prices for African-American and Hispanic borrowers who obtained residential mortgages between 2006 and 2011 from Provident's nationwide network of mortgage brokers.
Settlement Requires Substantial Improvements to Dealerships' Policies and Provides $225,000 in Relief to Affected Customers
The U.S. Department of Justice Civil Rights Division, the U.S. Attorney's Office for the Western District of North Carolina and the North Carolina Department of Justice today announced a settlement of the federal government's first-ever discrimination lawsuit involving "buy here, pay here" auto lending. The settlement, which is subject to court approval, was filed today in the U.S. District Court for the Western District of North Carolina.
WASHINGTON, D.C. – The Consumer Financial Protection Bureau (CFPB) today proposed several changes to its mortgage rules to facilitate responsible lending by small creditors, particularly in rural and underserved areas. If finalized, the proposal issued today would increase the number of financial institutions able to offer certain types of mortgages in rural and underserved areas, and help small creditors adjust their business practices to comply with the new rules. "Responsible lending by community banks and credit unions did not cause the financial crisis, and our mortgage rules reflect the fact that small institutions play a vital role in many communities," said CFPB Director Richard Cordray. "Today's proposal will help consumers in rural or underserved areas access the mortgage…
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