To gauge institutions that are financial compliance with HMDA needs, OCC assessment staff will concentrate on 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 areas given just below for banking institutions which can be susceptible to collecting, recording, and information that is reporting all HMDA information areas. screening for banking institutions that qualify for the partial exemption from HMDA information collection, recording, and reporting requirements will give attention to 21 key areas, since set forth below, and validate that the financial institution satisfies the requirements for a exemption that is partial. In a few circumstances, nevertheless, and in keeping with the FFIEC tips, assessment staff may figure out it is appropriate to examine extra HMDA data areas.
Proper reporting of HMDA information is essential in evaluating the precision for the HMDA data that banking institutions record and report. Where mistakes that exceed founded thresholds 10 are identified in a organization’s HMDA information, the OCC office that is supervisory discernment in needing the organization to fix certain errors, without requiring resubmission regarding the information. The office that is supervisory 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 one of the keys information industries that examiners will used to validate the precision regarding the HMDA Loan/Application join (LAR) for banking institutions which can be complete HMDA reporters and individually for banking institutions that qualify for the exemption that is partial.
As established in December 2017 for an interagency foundation, the OCC will not plan 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 with regards to mistakes in information gathered in 2018 and reported in 2019. Collection and distribution associated with 2018 HMDA information will give you banking institutions with a way to recognize any gaps inside their utilization of the amended Regulation C and also make improvements within their HMDA conformity administration systems money for hard times. Any exams of 2018 HMDA information may be diagnostic, to greatly help banks determine conformity weaknesses, therefore the OCC will credit compliance that is good-faith.
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 starting 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). 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, as well as 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 reasons behind denial from the HMDA Loan/Application join (LAR) irrespective of 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 data supplied in this bulletin supplements guidance released on August 25, 2017, through OCC Bulletin 2017-31, “FFIEC HMDA Examiner Transaction Testing instructions,” which shows examiners should direct a bank to improve any information industry in its HMDA that is full LAR any industry where in actuality the mistake price exceeds the stated resubmission limit. The financial institution are often needed in these instances to resubmit its HMDA LAR using the corrected information field(s). OCC examiners will talk to their supervisory workplace and, as relevant, OCC’s Compliance Supervision Management Division to ascertain whether resubmission is necessary centered on particular facts and circumstances.