How to Use the New CFPB HMDA Platform
Although the new CFPB HMDA rules can seem complex to navigate, the submission process is relatively straightforward, especially if you already use QuestSoft software.
The new CFPB HMDA platform was released in beta on November 3, 2017 and allows for institutions to create accounts and test their HMDA data for errors. In 2018, more than 3,000 institutions will submit their data to the CFPB using the new submission platform.
Since the process is new, we thought we would walk you through each step of the submission process as of now.
First, on January 1, 2018 or later, sign up for an account using your financial institution’s email address. You can sign up/login on the CFPB website here. (Note that accounts created during the beta period will be deleted on December 31, 2017.)
Once you are logged in, you can then upload your HMDA data as a pipe delimited file. Pipe delimited means that each data field within each row will be separated with a pipe character: “|”.
Your HMDA file should have a .txt file format extension. Many LOS’s and compliance programs such as Compliance RELIEF’s HMDA module will create the necessary file for you. The CFPB also released a File Format Verification Tool that allows you to make sure your file meets the formatting requirements.
The CFPB HMDA platform will then detect any syntactical, validity, quality and macro edits. You will be required to fix all detected edits before completing your submission. If you’re using QuestSoft software, you will be aware of these edits well in advance of submission, so you can get them addressed.
Here is what each HMDA edit means:
These are edits that check whether the loan/application register is in the correct format and whether the data covers the correct filing year. A syntactical edit occurs, for example, if none of the rows in the loan/application register begin with the number two (2) to indicate that the data fields which follow contain information relating to the reported loan or application.
This checks whether there are valid values in each data field. The data cannot be submitted until errors identified by the validity edits are corrected. For example, a validity edit occurs if the contact person’s telephone number does not follow the format “999-999-9999.”
Quality Edits check whether entries in the individual data fields or combinations of data fields conform to expected values. A quality edit occurs, for example, if the reported Tax Identification Number does not match the Tax Identification Number the institution reported on the previous year’s loan/application register.
These check whether the submitted loan/application register as a whole conforms to expected values. For example, a macro quality edit occurs if the reported percentage of multifamily loans exceeds 10% of the loan/application register entries.
If errors are found, you will be notified to fix the edits in your original file and reupload the file to the CFPB HMDA platform. Once all of the edits are fixed, an authorized representative of your institution must certify the accuracy and completeness of the data.
Once your HMDA data is certified by a member of your institution, you can submit your file to the CFPB.
According to the CFPB you can submit your HMDA data anytime between January 1st and March 1st, but many experts agree that the CFPB will be able to automatically analyze your HMDA submission to see what errors were fixed, detect any patterns of errors from previous submissions and will compare you to your peers instantly.
That is why it is imperative that you scrub your data clean before submitting it to the CFPB HMDA platform. There is a reason why over 70% of lenders choose Compliance RELIEF to manage and correct compliance errors before they become regulatory fines.
Compliance RELIEF allows you to perform a large amount of functions that the CFPB platform does not. For example, many institutions use multiple loan origination systems. Each LOS will have its own export file that will need to be consolidated into one pipe delimited file to upload. Compliance RELIEF allows you to import all of your loan records into one database and scrub the data for errors.
Another advantage of Compliance RELIEF is the ability to perform group edits and batch geocoding – enabling you to have peace of mind and save you time during your HMDA submission process.
So, don’t rely solely on the new CFPB HMDA Platform -- scrub and correct your errors before your regulators detects them!