ABA Banking Journal - September/October 2017 - 55

Submission of 2017 data
The entire submission process will
change for the submission of 2017
data on March 1, 2018. The new filing
requirements for submission on the
new CFPB HMDA platform are set forth
in the filing instruction guides available
on the bureau's website. Be prepared
for spending time to ensure that your
data edits (quality, validity, macro and/or
syntactical errors) are resolved, validated
and explained before you sit down to
submit. Plan time for any manual work to
enter this information into the portal, and
have a signing officer available to submit.
Any steps you can take to improve data
integrity now will help you significantly
in the hectic months of January
and February.

Expanded collection
of data in 2018
By now, you likely have systems, policies,
procedures and training underway to

start collecting the 110 data points for
loans closing in 2018. This would include
data relating to applicants, borrowers and
the underwriting process; the property
securing the loan; features of the loan;
and certain unique identifiers. You have
coordinated with the business lines and
the second and third lines of defense
to test the data frequently throughout
2018, and you're alert for any nuances
in collection, including any updates for
TRID tolerance cures occurring after loan
closure and loans started in 2017 that will
close and be reportable in 2018. Consult
the CFPB's "Summary of Reportable
Data" and "Reporting 'Not Applicable'"
guides for more.
The most complicated area to prepare
for is the collection and reporting of
information for ethnicity, race and gender.
Suffice it to say there is a lot evolving
here. In general, report ethnicity, race and
gender as provided, at the time provided.

(There are nuances for 2017 applications
that close in 2018.) Collect demographic
data from the applicant and the listed
first co-applicant only, who are individuals
(e.g., not corporations). Consult the
HMDA ethnicity and race collection and
reporting reference tool, Appendix B, and
stay alert for the April 2017 proposed
amendments being finalized.
By now, your cart should be overflowing
with information and guidance. Look to
the CFPB website for resources (many of
which have been referenced here) and
updates on evolving regulatory activity.
And as the game begins, let us hope we
will all be winners!
BARBARA BOCCIA, CRCM, is
senior director of U.S. advisory
services and regulatory relations
at Wolters Kluwer. This article is
intended only to act as a quick
reference and not as a substitute
for the law, regulations or official commentary.

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Table of Contents for the Digital Edition of ABA Banking Journal - September/October 2017