To guage institutions that are financial compliance with HMDA needs, OCC assessment staff will give attention to identified key data fields during transaction screening 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 areas. screening for banking institutions that qualify for a partial exemption from HMDA information collection, recording, and reporting requirements will give attention to 21 key areas, because set forth below, and validate that the lender fulfills the criteria for the exemption that is partial. In some circumstances, nonetheless, and in keeping with the FFIEC recommendations, assessment staff may figure out that it’s appropriate to examine extra HMDA information areas.
Proper reporting of HMDA information is essential in evaluating the precision of this HMDA data that banking institutions record and report. Where mistakes that exceed founded thresholds 10 are identified in an organization’s HMDA information, the OCC supervisory workplace has discernment in needing the organization to improve certain mistakes, without needing resubmission associated with the information. The supervisory workplace may need resubmission of HMDA information as soon as the inaccurate information are indicative of systemic interior control weaknesses that call into concern the integrity associated with organization’s whole HMDA data report.
The next table lists the main element information areas that examiners will used to confirm the precision associated with the HMDA Loan/Application enter (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 doesn’t plan to need information resubmission for HMDA data accumulated in 2018 and reported https://maxloan.org/title-loans-oh/ in 2019, unless information mistakes are product. Moreover, the OCC will not want to evaluate charges with regards to mistakes in information gathered in 2018 and reported in 2019. Collection and distribution of this 2018 HMDA information will give you banking institutions with a way to determine any gaps within their utilization of the amended Regulation C and work out improvements within their HMDA conformity administration systems money for hard times. Any examinations of 2018 HMDA information will soon be diagnostic, to simply help banks recognize conformity weaknesses, in addition to OCC will credit compliance that is good-faith.
More Information
Please contact Vonda J. 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 information on covered loans specified in 12 CFR 1003.4(a)(1)-(38) on that loan application register containing 110 information industries, as specified within the FFIEC Filing guidelines Guide (FIG). Make reference to FFIEC Resources for HMDA Filers for extra information.
7 The FFIEC members will be the FRB, FDIC, the OCC, the CFPB, the nationwide Credit Union management, and also 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 legal guidelines.
8 OCC-regulated banking institutions and their subsidiaries have to report good reasons for denial regarding the HMDA Loan/Application enroll (LAR) aside from partial exemption status. Relate 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 mistake price exceeds the stated resubmission limit. The financial institution can also be needed in these instances to resubmit the corrected data field(s to its HMDA LAR). OCC examiners will check with their supervisory workplace and, as applicable, OCC’s Compliance Supervision Management Division to find out whether resubmission is necessary according to particular facts and circumstances.
