The partial exemption is maybe maybe perhaps perhaps not offered to banking institutions that don’t meet specific Community Reinvestment Act performance assessment score criteria.

To gauge banking institutions’ compliance with HMDA demands, OCC assessment staff will give attention to identified key data fields during transaction assessment pursuant to HMDA for information gathered on or after January 1, 2018. Examination staff will concentrate on the 37 areas the following for banking institutions which are at the mercy of collecting, recording, and information that is reporting all HMDA information industries. Testing for banking institutions that qualify for a partial exemption from HMDA data collection, recording, and reporting requirements will concentrate on 21 key areas, because set forth below, and validate that the lender satisfies the criteria for the exemption that is partial. In a few circumstances, nonetheless, and in keeping with the FFIEC tips, assessment staff may figure out it is appropriate to examine extra HMDA information industries.

Proper reporting of HMDA information is crucial in evaluating the precision of this 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 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 organization’s entire HMDA data report.

The next table lists the main element data industries that examiners will used to validate the precision of this HMDA Loan/Application join (LAR) for banking institutions being complete HMDA reporters and individually for banking institutions that qualify for the partial exemption.

Compliance Statement

As established in December 2017 for an interagency basis, the OCC will not want to need information resubmission for HMDA data built-up in 2018 and reported in 2019, unless information mistakes are product. Also, the OCC doesn’t want to evaluate charges with regards to mistakes in information gathered in 2018 and reported in 2019. Collection and distribution associated with the 2018 HMDA information provides banking institutions with a way to recognize any gaps within their utilization of the amended Regulation C and also make improvements inside their HMDA conformity administration systems money for hard times. Any examinations of 2018 HMDA information are going to be diagnostic, to aid banks recognize car title loan MN conformity weaknesses, together with OCC will credit good-faith conformity efforts.

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, banking institutions susceptible to the HMDA will collect 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 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, and also the continuing State Liaison Committee. The FFIEC users promote conformity with federal customer protection legal guidelines through supervisory and outreach programs. The HMDA is among these statutory regulations.

8 OCC-regulated banking institutions and their subsidiaries are required to report reasons behind denial regarding the HMDA Loan/Application enroll (LAR) aside from 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 information and knowledge provided in this bulletin supplements guidance released on August 25, 2017, through OCC Bulletin 2017-31, “FFIEC HMDA Examiner Transaction Testing tips,” which shows examiners should direct a bank to fix any information industry with its full HMDA LAR for any industry where in actuality the mistake price exceeds the stated resubmission limit. The lender are often needed in such instances to resubmit its HMDA LAR with all the corrected information field(s). OCC examiners will talk to their office that is supervisory and as relevant, OCC’s Compliance Supervision Management Division to ascertain whether resubmission is needed predicated on particular facts and circumstances.