CFPB won’t require resubmission for errors in data collected under HDMA

The Consumer Financial Protection Bureau (CFPB) said it will not require data resubmission for errors in data collected under the Home Mortgage Disclosure Act (HMDA) unless those errors are substantial or assess penalties.

HMDA requires lenders to report information on applications they receive for certain types of mortgage loans. The Dodd-Frank Wall Street Reform and Consumer Protection Act directed the CFPB to expand the amount of data collected. Among the new types of data required to be collected, the bureau sought additional information regarding mortgage loan underwriting and pricing.

Thus, the bureau issued a rule in 2015 that requires financial institutions to collect and report additional mortgage information beginning on Jan. 1, 2018. In August 2017, the bureau increased the threshold for collecting and reporting data on home equity lines of credit for two years.

However, the bureau, under new leadership, now acknowledges that significant operational challenges exist to meet the impending requirements under the rule. So, for HMDA data collected in 2018 and reported in 2019, the bureau does not intend to require financial institutions to resubmit data unless data errors are material, or to pay penalties with respect to data errors.

For data collected in 2017, companies should submit their data in accordance with current Regulation C. Further, they will submit data using the bureau’s new HMDA Platform – an online portal to the required information.

The bureau also intends to reconsider various aspects of the 2015 HMDA rule such as the institutional and transactional coverage tests and the rule’s discretionary data points. It may re-examine lending-activity criteria that determine whether institutions are required to report mortgage data and adjusting the requirements to report certain types of transactions.

In addition, the CFPB may re-assess the additional information that the rule requires beyond the new data points specified under the Dodd-Frank Act.