7 Helpful Tips for Submitting Your HMDA Data to the CFPB
During the last two weeks of February, our support department receives an enormous amount of calls from lenders who need help or have questions about submitting their HMDA data to the CFPB. With the new HMDA rules in effect — and with lenders submitting three times the amount of data — we anticipate that there will be some road bumps along the way. As a result, we have compiled some helpful tips for lenders to make sure March 1st is just another day.
Test Your HMDA Submission Early
Even though the beta period is closed and the beta site is no longer available, the HMDA Platform can still be used for testing purposes. Financial institutions can upload data and review edits as many times as they need to before the filing period deadline. Data that is uploaded but not electronically signed and submitted is not maintained in the Platform. In our testing, the Google Chrome browser has performed best with the CFPB Platform. Customers using Microsoft Internet Explorer, have reported issues with not being able to replace data.
Submitting early ensures that you do not experience long upload times as everyone tries to use the Platform during the last two weeks of February.
Use the Correct LEI
Each institution absolutely needs a Legal Entity Identifier (LEI) before they can use the HMDA Platform. The LEI needs to be obtained by a licensed LEI provider, and it is NOT the same as their 2017 & prior Respondent ID. More information can be found on our HMDA Headquarters.
Please be careful to distinguish between zeroes “0” and the letter “O” capital “I” and small “l” which look very much the same. It is best to tab into the LEI field and copy and paste the LEI.
Use the Correct Agency Code
One of the most common errors we see is people mistakenly choosing Agency Code 9 (CFPB). In most cases, this is not correct. The Agency Code 9 should only be selected if you are actually affiliated with a CFPB regulated entity or more than 10 billion in assets. See: Institutions subject to CFPB supervisory authority.
Non-depositories that are not affiliated with any depository institutions should always report Agency Code 7 (HUD).
Report GMI Consistently
Many compliance officers have been encountering inconsistent collection of the expanded demographic data. This year, the CFPB will accept NA for GMI, due to the confusion surrounding collection methods.
Verify Your File Format
We encourage lenders to check their formatting using the File Format Verification Tool prior to uploading to the HMDA Platform. Working out any formatting issues ahead of time will make the submission process much easier and reduce the chance of upload errors.
The File Format Verification Tool will verify that your file is 1) pipe-delimited; 2) has the proper number of data fields; and 3) has data fields formatted as integers, where necessary. You can also create a hmda.txt file for verification from the Import/Export => Export CFPB screen in HMDA RELIEF.
Know the Validation Process
The file validation process moves from 1) Uploading, to 2) Checking formatting, to 3) Validating edits. Once the first upload step is completed, users can close their browser & come back later to view the results of the validation. Do not close the browser while the file is still uploading.
Clear Your Cache When Re-Uploading
If lenders are trying to upload a file and it appears that the new file is not overwriting their last upload, they should clear their browser’s cache and try the upload again.
We hope these tips help aid you in submitting your HMDA data to the CFPB!
If you experience trouble with the HMDA Platform, we recommend you contact firstname.lastname@example.org.
If you have some additional tips for us to share, send them to email@example.com.