FFIEC Announces Release of 2019 HMDA Data

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On June 24, 2020, the Federal Financial Institutions Examination Council (FFIEC) announced the release of the 2019 Home Mortgage Disclosure Act (HMDA) data. This is early. In recent years the data were released in August or September, although the 2017 data were released in May. 2019 is the second year for which institutions were required to collect and report data under the expanded information requirements adopted by the CFPB in the October 2015 HMDA rule amendments.

The CFPB also issued its third annual data point report. The report addresses mortgage market activity and trends based on the 2019 HMDA data.

A total of 5,508 reporting institutions (a decline of about 3% from 2018) reported information on 15.1 million home loan applications. As previously reported, the Economic Recovery, Regulatory Relief, and Consumer Protection Act (Growth Act) created a partial exemption from HMDA reporting for smaller volume bank and credit union lenders. Basically pursuant to the exemption, a qualifying lender may elect to report only the HMDA data fields that existed before the October 2015 HMDA rule amendments. The FFIEC reports that 2,494 reporting institutions relied on the partial exemption for at least one of the 26 data points that need not be reported under the exemption.

The CFPB is expected to release a proposal this summer to amend the HMDA data that institutions must collect and report.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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