To judge institutions that are financial 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 down the page for banking institutions which are susceptible to collecting, recording, and reporting information for all HMDA information areas. Testing for banking institutions that qualify for the partial exemption from HMDA information collection, recording, and reporting requirements will consider 21 key industries, because set forth below, and validate that the financial institution meets the requirements for the partial exemption. In some circumstances, but, and in line with the FFIEC instructions, 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 for the HMDA data that finance institutions record and report. Where mistakes that exceed founded thresholds 10 are identified within an organization’s HMDA information, the OCC supervisory office has discernment in needing the organization to improve particular mistakes, without needing resubmission associated with information. The office that is supervisory need resubmission of HMDA information once the inaccurate information are indicative of systemic interior control weaknesses that call into concern the integrity regarding the organization’s whole HMDA data report.
The next table lists one of the keys information areas that examiners will used to validate the precision regarding the HMDA Loan/Application enroll (LAR) for banking institutions being 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 want to need information resubmission for HMDA data accumulated in 2018 and reported in 2019, unless information errors are product. Moreover, the OCC will not plan 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 offer banking institutions with a way to recognize any gaps inside 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 are car title loan SD going to be diagnostic, to assist banks determine conformity weaknesses, while the OCC will credit good-faith conformity efforts.
Please contact Vonda J. Eanes, Director for CRA and Fair Lending Policy, Compliance danger Policy Division at (202) 649-5470.
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 a loan application register containing 110 information areas, 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, therefore the continuing State Liaison Committee. The FFIEC users promote conformity with federal customer security legal guidelines through supervisory and programs that are outreach. The HMDA is among these statutory legal guidelines.
8 banks that are OCC-regulated their subsidiaries have to report cause of denial from 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 details supplied in this bulletin supplements guidance released on August 25, 2017, through OCC Bulletin 2017-31, “FFIEC HMDA Examiner Transaction Testing directions,” which suggests examiners should direct a bank to improve any information industry with its full HMDA LAR for any industry in which the mistake price exceeds the stated resubmission limit. The financial institution can also be required in these instances to resubmit the corrected data field(s to its HMDA LAR). OCC examiners will check with their office that is supervisory and as relevant, OCC’s Compliance Supervision Management Division to ascertain whether resubmission is necessary according to certain facts and circumstances.
