Breaking News!!
This week the OCC, FRB and FDIC announced their stance on HMDA reporting for institutions thrown back into HMDA reporting due to the recent Court decision to roll back the closed-end mortgage reporting threshold from 100 back to 25. All three regulators are taking the same stance as the CFPB and have stated that they have no plans to cite institutions for not filing a HMDA LAR for 2020, 2021, and 2022. Read the bulletins here:
Census Tract Updates
HMDA reporters are in the process of validating their HMDA data for accuracy there is one item which comes to mind regarding the geocoding of the property addresses. The LAR has two sections that required numerical codes of the property location as noted below.
The location data fields are the County which is the five-digit code and the Census Tract which is the 11-digit code.
Smaller volume HMDA reporters that utilized the FFIEC/CFPB HMDA LAR formatting tool to record their HMDA loans most likely (should) rely on the geocoding tool located on the FFIEC website.
From January 1, 2022, to August 25, 2022, the only geocoding information available on the FFIEC website was 2021 geocode data. It was not until August 26, 2022 that the FFIEC’s Geocode Tool was updated with the current 2022 Census Tract data. The updated 2022 data included new Tracts and also deleted Tracts.
TCA recommends any HMDA reporter who manually obtained geocodes from the FFIEC website prior to August 26, 2022, re-geocode the property address locations for that time this period to ensure that the five-digit county codes and the 11-digit census tract codes are accurate with the year 2022.
HMDA reporters utilize a HMDA software program like HMDAWiz, QuestSoft (now Ncontracts), or RATA to record the required loan information into the applicable data fields. These software programs have a geocoder program which geocodes the property address for both the five-digit county codes and the 11-digit census tract codes.
TCA recommends these HMDA reporters to re-run their 2022 HMDA LAR through their software’s geocoder program to ensure the current 2022 five-digit County codes and the 11-digit Census Tract codes are accurate.
Has your HMDA filing status changed for 2023? Institutions who have exceeded the 25 closed-end mortgage loan threshold in each of the prior two calendar years, be prepared to file HMDA data for 2023 in March 2024. This may require changes to policies, procedures and updated training if your institution has been out of the HMDA game for the past couple of years.
As always, TCA is A Better Way to be in compliance. Contact us today at (800) 934-7347 or [email protected].
