To gauge institutions that are financial compliance with HMDA needs, OCC assessment staff will concentrate on identified key data fields during transaction evaluation pursuant to HMDA for information gathered on or after January 1, 2018. Examination staff will concentrate on the 37 industries given just below for banking institutions which are susceptible to collecting, recording, and information that is reporting all HMDA information industries. Testing for banking institutions that qualify for a partial exemption from HMDA information collection, recording, and reporting requirements will give attention to 21 key industries, since set forth below, and validate that the lender satisfies the requirements for a exemption that is partial. In some circumstances, nevertheless, and in line with the FFIEC directions, assessment staff might figure out that it’s appropriate to examine extra HMDA information fields.

Proper reporting of HMDA data is crucial in evaluating the precision of this HMDA data that banking institutions record and report. Where errors that exceed founded thresholds 10 are identified within an organization’s HMDA information, the OCC supervisory workplace has discernment in needing the organization to improve particular mistakes, without needing resubmission for the information. The supervisory workplace may need resubmission of HMDA information once the inaccurate information are indicative of systemic interior control weaknesses that call into concern the integrity associated with the organization’s whole HMDA data report.

The next table lists the main element information industries that examiners will used to confirm the precision for the HMDA Loan/Application join (LAR) for banking institutions which are complete HMDA reporters and individually for banking institutions that qualify for the partial exemption.

Compliance Statement

As established in December 2017 for an interagency foundation, the OCC will not want to need information resubmission for HMDA data gathered in 2018 and reported in 2019, unless information mistakes are product. Also, the OCC will not want to evaluate charges pertaining to mistakes in information gathered in 2018 and reported in 2019. Collection and distribution regarding the 2018 HMDA data provides banking institutions with a way to recognize any gaps within their utilization of the amended Regulation C and work out improvements inside their HMDA conformity administration systems money for hard times. Any exams of 2018 HMDA information is likely to be diagnostic, to greatly help banks recognize compliance weaknesses, as well as the OCC will credit good-faith conformity efforts.

More Information

Please contact Vonda J. quick Nebraska loan Eanes, Director for CRA and Fair Lending Policy, Compliance danger Policy Division at (202) 649-5470.

Grovetta N. Gardineer Senior Deputy Comptroller for Bank Supervision Policy

6 you start with information gathered on or after January 1, 2018, finance institutions susceptible to the HMDA will gather and report data on covered loans specified in 12 CFR 1003.4(a)(1)-(38) on that loan application register containing 110 data industries, as specified into the FFIEC Filing guidelines Guide (FIG). Relate to FFIEC Resources for HMDA Filers for more information.

7 The FFIEC members would be the FRB, FDIC, the OCC, the CFPB, the nationwide Credit Union management, additionally the State Liaison Committee. The FFIEC users promote conformity with federal customer security legal guidelines through supervisory and outreach programs. The HMDA is among these regulations.

8 banks that are OCC-regulated their subsidiaries have to report known reasons for denial from the HMDA Loan/Application enter (LAR) no matter partial exemption status. Make reference to 12 CFR 27 (nationwide banking institutions) and 12 CFR 128.6 (federal discount associations).

9 83 Fed. Reg. 45325.

10 the info supplied in this bulletin supplements guidance released on August 25, 2017, through OCC Bulletin 2017-31, “FFIEC HMDA Examiner Transaction Testing instructions,” which suggests examiners should direct a bank to improve any information industry with its full HMDA LAR for any industry where in fact the error price exceeds the stated resubmission threshold. The financial institution can also be needed in such instances to resubmit its HMDA LAR utilizing the corrected information field(s). OCC examiners will check with their supervisory workplace and, as relevant, OCC’s Compliance Supervision Management Division to ascertain whether resubmission is necessary according to particular facts and circumstances.