On August 21, 2020, the CFPB released the 2021 HMDA Filing Instructions Guide (FIG) for data collected in 2020 and reported in 2021. Besides changing the references of “2020” to “2021,” the other changes are less cosmetic, such as updated descriptions and instructions for certain fields and revisions to certain edits.
Also, we note they added a new Automated Underwriting System code 7 – Internal Proprietary System.
We’re sure there will be more changes to come from lessons learned during the 2020 filing. Be sure to update any applicable training.
Along with the 2021 FIG, the Bureau also released an updated Supplemental Guide for Quarterly Filers, focusing on the required quarterly reporting for financial institutions that reported a combined total of at least 60,000 applications and covered loans, excluding purchased covered loans, for the preceding calendar year. In addition to the annual data submission, these larger-volume reporters will submit HMDA data for each of the first three quarters of the year on a quarterly basis.
This supplemental guide outlines the areas and edits which differ from the instructions provided in the 2021 FIG and include a link to the Statement on Supervisory and Enforcement Practices Regarding Quarterly Reporting Under the Home Mortgage Disclosure Act which was released in response to COVID-19 as of March 26, 2020; until further notice, the Bureau announced that it does not intend to cite in an examination or initiate an enforcement action against any institution for failure to report its HMDA data quarterly.
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