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While the revised HMDA rules do not go into effect until January 1, 2018, there are changes for 2017 that will affect your process, even if your financial institution uses vendor software for your HMDA LAR creation and submission. Those changes go into effect January 1, 2017! It is important to understand what is changing and to be prepared!
- The file format will be a pipe delimited text format, not the space delimited .dat file format that has been in use. This will affect both those with manual processes and those whose vendor does not provide a pipe delimited file extract.
- The downloadable FFIEC software is being discontinued; it is being replaced by an online process that involves uploading a pipe delimited text file. This online submission will be the only acceptable method to submit a HMDA file.
- Institutions with manual processes will need to gather data in a spreadsheet.
- Each HMDA reporting financial institution will have to register to gain access to the new HMDA reporting platform.
- Edits will be run interactively, with a downloadable report available. There will be no emailing or faxing of edits after the fact! No more beating the deadline and addressing edits after you have filed.
- The new process includes an online officer certification of the data.
- The final submission process will have to be pushed back if your institution needs to file at the last minute because of the changes to the edit process.
- The revised application form (URLA, 1003) can begin to be used as of January 1, 2017 with the expanded race and ethnicity fields, with caveats on reporting this data.
- Submissions will go to the CFPB, not to the FRB as in the past.
Will your financial institution be ready? Will you have a revised process in place to being gathering and testing data?
This webinar will walk through the intricacy of these changes and their implications for your process.
Who Should Attend:
- Lending and operations staff involved in LAR input
- Compliance Staff
- HMDA Testing Staff
- Management with HMDA oversight responsibilities
- Solutions providers
2017 HMDA Process Changes: What You Need to Know
Filing instructions guide for HMDA data collected in 2017 OMB
HMDA Sample - LAR
Questions and Answers