HMDA Changes Happen January 1, 2018
Beginning January 1, 2018, Credit Unions who originate at least 25 purchase loans, including refinances of home purchase loans, and who do not meet any of the exemptions are subject to Regulation C, and the data that Credit Unions collect in or after 2017 have a new submission process with the Consumer Financial Protection Bureau (CFPB).
The new process requires:
- Credit Unions begin reporting data to CFPB.
- The file needs to be pipe delimited text. (This is an available feature from Mortgage Cadence.)
- Credit Unions must submit the HMDA report using web interface, the HMDA platform.
- Credit Unions must complete a Web-based report edit prior to submitting HMDA data.
- An authorized officer of the Credit Union must certify the HMDA report.
- Credit Unions must obtain and use a special Legal Entity Identifier (LEI) when reporting data.
New Demographic Data and data points must be included in the HMDA extract beginning January 1, 2018. This is the data that will be reportable on loans with a Final Action of 1/1/2018 or later. Mortgage Cadence enhancements include new editors, screens in the consumer application, and screens in the workbench and path. Configured updates will be available beginning January 1, 2018. MMS will provide additional information and training in the near future to assist with collection of required data.
Complete filing instructions may be found at https://www.consumerfinance.gov/data-research/hmda/static/for-filers/2017/2017-hmda-fig.pdf