HMDA

Every fair lending and CRA software evaluation starts the same way: a shortlist of vendors, a run of demos that all look competent, and a decision that has to be defended internally on something firmer than which interface felt nicer. The difficulty is that the differences between these products are mostly invisible in a demo. They show up eighteen months later, in an examination, when someone asks how a number was produced and the honest answer turns out to be that nobody knows. This is a guide to testing for that in advance. It is written from our side of the table — we sell one of these products — so treat the last section as the interested party it is. The first five are the questions we would ask any vendor in this category, including ourselves. What does fair lending…

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The short version. If you have been told HMDA Plus is coming, the date is wrong by about a decade. It is the industry nickname for the expansion the CFPB proposed in 2014 and finalised on 15 October 2015, and most of it took effect on 1 January 2018. It is not a proposal you need to prepare for. It is the reason your LAR looks the way it does now. That matters more than a correction, because a good deal of the material still circulating about it is written in the future tense. If your process was built after 2018 you inherited the outcome without seeing the transition; if it was built before, some of the workarounds from that first filing season are probably still in it. Either way the useful question is not what HMDA Plus proposed. It is what it did to the workflow, and which of those…

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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 range from simple data entry mistakes to logic conflicts between fields that need careful analysis to resolve. After helping institutions file HMDA data for nearly four decades we see the same ones appear again and again, and the pattern behind most of them is not carelessness but a mapping between an origination system and the LAR that was defined once and never revisited. Here is how to identify and fix the ten most common HMDA edit check errors before they delay your submission. Every edit number below is quoted from the FFIEC Filing Instructions Guide for 2026, which is linked at the end. Understanding HMDA Edit…

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Status note, updated 18 August 2026. This checklist was written for the 2025 data / March 2026 filing cycle, and that cycle has closed — the dates below are kept as a worked example rather than as upcoming deadlines. The eight preparation steps themselves do not change from year to year, so the checklist is still the one to work through. For the 2026 data year, the filing deadline is 1 March 2027, which falls on a Monday and so needs no adjustment. The March 2, 2026 deadline for submitting your 2025 HMDA data is a Monday, and that is the only reason it is not March 1: the usual date falls on a Sunday this year. Whether this is your first filing or your thirtieth, working through a structured preparation process is what keeps the last week of February from turning into a…

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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…

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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…

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As part of the upcoming HMDA changes, we are getting a lot of inquiries on two topics in particular. 1) Handling of the HMDA 2017 data submission in February 2018. There are no data changes to the HMDA 2017 data being submitted in February 2018. The only change to the HMDA 2017 submission is that the submission file itself will go from the current fixed-length record format to a pipe "|" delimited format. This change will be available in version 17 of the Comply software, to be released in 2017. 2) In regards to the Universal Loan Identifier (ULI), RATA Comply will be able to accept loans for 2018 either with or without ULI. As part of the Reporting Entity (RE) properties in Comply there will be a field for the Legal Entity ID (LEI). During the import process all loans that are not Action…

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