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Quarterly Submission Information for Required Institutions

March 13, 2020 RATA Associates Compliance Team Editorial standards 4 min read ⇠ All Articles

Beginning January 1, 2020, the 2015 HMDA Final Rule requires quarterly reporting for financial institutions that reported a combined total of at least 60,000 applications and covered loans, excluding purchased covered loans, for the preceding calendar year. Thus, in addition to their annual data submission, these larger-volume reporters will submit HMDA data for each of the first three quarters of the year on a quarterly basis.

If you meet the criteria for quarterly submissions, Comply’s HMDA reporting software is ready for you to begin that process. Simply follow the same processes you would for your annual submission process, perform geocoding operations, rate spread calculations, edit checks, etc...

Once you are ready to submit, simply go through the submission wizard and Comply will automatically detect that a quarterly submission is underway and ask you to confirm that your institution meets the threshold requirement for quarterly submission. If so, you will be advised as to which quarter is being created and allow you to select between the quarter-only or year-to-date submission methods. The remainder of the wizard is the familiar process followed for the annual submission.

A video has been prepared that can also be of help. In the Resources section on the Comply Start Page, click on Video Training then expand New Comply 19 Videos. Near the bottom of the list you will find Submission – Quarterly HMDA Submissions.

For additional information regarding the quarterly submission requirements please visit:
https://s3.amazonaws.com/cfpb-hmda-public/prod/help/supplemental-guide-for-quarterly-filers.pdf

The chart below shows the quarterly filing dates for required institutions:

Quarter 1 Filing Period

Quarter 1 reporting includes all covered loans and applications with a final action

taken date between January 1st (01/01) and March 31st (3/31).

Quarter 1 Filing Deadline: May 30th (60 calendar days from March 31st).

Quarter 1 Discrete Filing Period: April 1st – May 30th.

The HMDA Platform opens to accept Quarter 1 Filings on the first calendar day of Quarter 2 (April 1st).
The HMDA Platform accepts Quarter 1 Filings through the filing deadline of May 30th. Late submissions may be accepted between May 31st and June 30th.

Quarter 2 Filing Period

Quarter 2 reporting includes all covered loans and applications with a final action taken date between April 1st (04/01) and June 30th (06/30). Institutions are permitted to report cumulative data, meaning that the Quarter 2 file can include both Q2 and Q1 data.

Quarter 2 Filing Deadline: August 29th (60 calendar days from June 30th).

Quarter 2 Discrete Filing Period: July 1st – August 29th.

The HMDA Platform opens to accept Quarter 2 Filings on the first calendar day of Quarter 3 (July 1st).
The HMDA Platform accepts Quarter 2 Filings through the filing deadline of August 29th. Late submissions may be accepted between August 30th and September 30th.

Quarter 3 Filing Period

Quarter 3 reporting includes all covered loans and applications with a final action taken date between July 1st (07/01) and September 30th (09/30). Institutions are permitted to report cumulative data, meaning that the Quarter 3 file can include Q3, Q2, and Q1 data.

Quarter 3 Filing Deadline: November 30th (60 calendar days from September 30th).

Quarter 3 Discrete Filing Period: October 1st – November 30th.

The HMDA Platform opens to accept Quarter 3 Filings on the first calendar day of Quarter 4 (October 1st).
The HMDA Platform accepts Quarter 3 Filings through November 30th. Late submissions may be accepted between November 30th and December 31st.

Quarter 4/Official Submission

Sixty days after the end of the fourth calendar quarter coincides with March 1, the date by which all financial institutions must submit their annual HMDA data pursuant to Ã‚Â§ 1003.5(a)(1)(i). Financial institutions subject to the quarterly reporting requirements in Ã‚Â§ 1003.5(a)(1)(ii) will report their fourth quarter (October 1st – December 31st) data as part of their annual submission. In its annual submission, a quarterly reporter will resubmit the data previously submitted for the first three calendar quarters of the year, including any corrections to the data, as well as its fourth quarter data.

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