HMDA
How to Fix the 10 Most Common HMDA Edit Check Errors
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. The article follows two official documents. Every edit number, permitted value and condition comes from the edit specifications in Section 5…
HMDA enforcement defanged by Trump-led regulators
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…
CFPB Issues Public Statement on HMDA Compliance
December 21, 2018 HMDA, which was originally enacted in 1975, requires many lenders to report information with respect to applications they receive for certain types of mortgage loans and certain loans that they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…
2017 Submission format and 2018 Universal Loan ID (ULI) information
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…
Comply 365 Newsletter: Edition #2
The new edition of the "Comply 365" newsletter has been released to give you the latest news on what's happening at RATA Associates.
- California's New Fair Lending Exam Law: What State-Chartered Banks, Credit Unions and Mortgage Licensees Should Have Ready
- How to Benchmark Your CRA and HMDA Lending Against Peer Data
- HMDA vs CRA vs Section 1071: What Each Rule Collects and Who Has to File
- Fair Lending Regression Analysis: What It Controls For and How to Explain a Pricing Disparity
- 2026 HMDA Data: Your Filing Checklist for the March 1, 2027 Deadline
- HMDA Plus: What It Actually Changed in the LAR Workflow
- CFPB and DOJ Settle Redlining Claims Against Non-Depository Mortgage Companies Before Change in Administration
- CFPB, DOJ Order Trident Mortgage Company to Pay More Than $22 Million for Deliberate Discrimination Against Minority Families
- How to Evaluate Fair Lending and CRA Software: What to Test Before You Sign
- What a Fair Lending Exam Actually Asks For
- Fair Servicing: What Examiners Test in Servicing Data, and How to Test It First
- What Actually Counts as a Small Business Loan Under Section 1071
- Section 1071 in 2026: What Lenders Need to Know About Small Business Lending Data
