Like last year, I want to write another blog to recap the year’s HMDA developments and look ahead to what’s coming in 2020. This year’s blog will summarize three different fronts: 1) data collection, 2) Reg C changes, and 3) disclosure of public data. In each area, I’ll describe the major developments over the last year or so and discuss the outlook for 2020.
The 2019 Filing Instruction Guide (FIG) from the CFPB, reflecting an update based on S.2155, is here. The 2020 FIG is here. The collection requirements for quarterly filing for large reporters go into effect in 2020. These affect lenders with more than 60,000 HMDA applications annually, with the first quarterly submission due May 30, 2020. For those lenders who are below the thresholds, there are no substantive collection changes between 2019 and 2020.
Reg C in flux
Beyond 2020, there is a lot of uncertainty for institutions about which transactions will be reportable and what fields will be part of the HMDA dataset. The 2019 year brought two related rules from the CFPB:
- On May 8, 2019, there was an Advance Notice of Proposed Rulemaking about possible changes to the set of fields that will be required to be collected. The CFPB is also considering eliminating the requirement that commercial-purpose transactions that are secured by multi-family dwellings be reported. The comment period closed in July 2019, and a related NPRM has not yet been issued. After that, a final rule could be issued.
- On May 13, 2019, there was a Notice of Proposed Rulemaking (NPRM) about the open-end and closed-end reporting thresholds that would require institutions to report one or the other, or both. The comment period closed in October 2019, but the rule has not yet been finalized.
Disclosure of public data
Believe it or not, the 2017 dataset is only now becoming static. The CFPB has said that it would allow submissions until the end of 2019…The past year has brought the initial release of the 2018 data, although lenders can submit their 2018 data until the end of 2020…In 2020, assuming the CFPB follows the same release schedule as 2019, we are looking forward to a “snapshot” release of the public 2019 dataset around August 2020…With respect to the 2020 data, the timing of the public release of the quarterly filings is something we will track closely.
There is so much to be excited about in 2020!