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COVID-19's Impact on Regulatory Reporting and Examinations for Mortgage Lenders

May 4, 2020 by Loretta Kirkwood

Regulators have been quick to issue guidance over the past few weeks due to the COVID-19 pandemic. However, it can be confusing to keep track of what is expected and what has been delayed or suspended with regard to supervisory activities and regulatory reporting. Regulators have continued to emphasize that working with consumers is the most important thing a lender can do, but many are continuing to conduct compliance examinations, albeit in different forms or manners.


To reduce any confusion, let’s outline what has been delayed, suspended or not impacted.


HMDA Reporting

This year, larger institutions that met specific reporting thresholds were expected to begin submitting  HMDA data quarterly. On March 26, the CFPB announced that due to the COVID-19 pandemic, they will not cite or initiate enforcement action against lenders that fail to submit quarterly data. However, lenders should continue to collect and record HMDA data for annual submissions. It is important to note that there is no option for voluntary quarterly submission. Only institutions that meet the 60,000 LAR threshold will be able to submit data using the CFPB HMDA Platform.


NMLS and SCMLS Call Reports

The quarterly reporting deadlines for both NMLS Mortgage Call Reports and SCMLS mortgage logs have been extended.

  • For NMLS Mortgage Call Reports, the May 15 deadline has been extended to June 14.
  • SCMLS has extended the March 31 submission deadline to June 1.

Examinations

While the Federal Reserve stated it is temporarily reducing its examination activities specifically for smaller banks, prudential regulators and the CFPB have all indicated that they will work with institutions to minimize disruptions while continuing to conduct examinations off-site.


Although the priorities of many lenders have shifted, it’s more important than ever to understand your risk and maintain strong compliance systems. Contact us today to see how our compliance solutions can help analyze and report your data. In the meantime, we will do our best to keep this blog post updated with the latest information.

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