CFPB Provides First Look at the HMDA Portal

by Ballard Spahr LLP
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On August 3, 2017, the Consumer Financial Protection Bureau (CFPB) provided the mortgage industry with a first look at the portal to be used for the reporting of, and public access to, data under the Home Mortgage Disclosure Act (HMDA).  Reporting institutions will use the portal to submit data commencing with the submission of calendar year 2017 data by March 1, 2018.  Also, instead of making their HMDA report and modified Loan Application Register (LAR) available to the public, reporting institutions will direct members of the public to the HMDA portal for this information.  The presentation was conducted by Michael Byrne, a Project Director in the Technology Division with the CFPB.  The presentation addressed only the data submission aspects of the portal, and not the ability to access HMDA data that is publicly available.

The portal was created by the CFPB in conjunction with the significant revisions to the HMDA rule.  As we have reported previously, most of revisions are scheduled to be implemented on January 1, 2018.  Nevertheless, initially the portal will be available only for the submission of the current HMDA data fields, which must be collected for 2017 activity and reported in 2018.

The portal is not yet available for access.  Mr. Byrne advised that the CFPB plans to make a Beta version of the portal available around the end of the third quarter, and that the CFPB will use input from the Beta period to revise the portal during the fourth quarter prior to the final version being released.  The CFPB also plans to release a check digit tool for use in verifying the universal loan identifier, and a geocoder tool, during the fourth quarter.

Once the portal becomes live, persons responsible for HMDA reporting at their institution will need to create an account to be able to access the portal.  The portal includes a series of steps to validate the accuracy and correct formatting of the data in a LAR before it can actually be submitted.  The CFPB has a File Format Verification Tool that institutions can use to test whether their 2017 HMDA data is formatted correctly.   The CFPB plans to issue a File Format Verification Tool for the revised HMDA data categories.  Data for the revised categories will first be collected for the 2018 reporting year, and reported in 2019.

Mr. Byrne advised that for institutions with a smaller volume of loans who elect to use the Excel-based LAR Formatting Tool that is available on the CFPB website, the CFPB designed the tool to convert the data into the format necessary to submit the data through the HMDA  portal.  The CFPB plans to issue a version of the LAR Formatting Tool for the revised HMDA data categories later this year.

For institutions that collect HMDA data with multiple LARs, they will be able to use the multiple LARS to test the data on the portal before submission.  However, to submit the data institutions will need to combine the multiple LARS into a single LAR file.

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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