-- Download New HMDA Platform Effective 1/1/2017 as PDF --
The new HMDA Platform goes into action January 1, 2017. The actual reporting rules for 2017 HMDA are not changing – the same codes and responses will be reported following current rules. The overall file format and the process to prepare and submit the data is changing. This affects individual field setup, if you create your own LAR, as well as the overall file submission process.
The familiar FFIEC HMDA software will not be utilized after the 2016 data submissions in early 2017. Data collected for calendar year 2017 will utilize a web-based (online) data submission and edit-check system. This new web-based system is called the “HMDA Platform”. Effective with the 2017 data, no other submission formats will be accepted.
For 2018 data and beyond, the same type of system will be used, but of course the data will be the revised HMDA rules will be followed.
Registration to use the HMDA Platform
HMDA filers will have to register online to obtain login credentials and establish an account prior to using the new system that will be effective January 1, 2017. This new registration provides security not present in the current system. Instructions for this registration will be published at a later date.
HMDA filers will, once registered and signed in, be able to upload the HHMDA LAR, confirm the filing stage of the LAR, run edits and check data validity, and lastly will be able to submit the HMDA LAR.
Filing institutions will certify the accuracy and completeness of the LAR online.
Details on this new online HMDA Platform to be used as of 1/1/2017 will be provided by the CFPB before year end.
Interacting with the HMDA Platform
The new online system will walk filers through the filing process. Edits will be provided and addressed online, even at the submission stage. There will be no emailing or faxing of edits.
Submitting a HMDA file
Financial institutions will select the HMDA LAR to be uploaded from a local or network file. The latest uploaded file will override any previously uploaded unsubmitted file.
Files that are not in the required pipe delimited format with the correct number of data fields will trigger an error message. The data will have to be corrected and uploaded again.
Creating Pipe Delimited Text Files
As of 1/1/2017, HMDA LAR files must be in a pipe delimited text file. The current space delimited “dat” file will no longer be used. The CFPB will provide a HMDA LAR formatting tool to assist in creation of pipe delimited files. This will be useful for financial institutions that do not utilize vendor software that will provide the required file format. Information on this tool will be released by the CFPB.
The online HMDA Platform will ensure that the HMDA LAR is accurate and complete via an online interactive process. Filers will be informed of the current stage of the review, items that need to be corrected, and what the next steps are for completing the submission of the final HMDA LAR. Edits will be reported back to the institution at each stage via the online Platform.
For data collected in 2017, the edits are listed in Section 4 of the FIG for HMDA data collected in 2017. Edits for data collected in 2018 will be released at a later date.
The 2017 and 2018 FIGs are available at this link.
Syntactical and validity edit review
The HMDA Platform will notify the institution of the syntactical or validity edits and identify the affected rows. A list of edits will be available for download.
All syntactical and validity edits must be addressed prior to submission. Once changes have been made, the revised pipe delimited file will be revealed via the HMDA Platform and rechecked at that time.
Quality and macro quality edits
After confirmation that there are no syntactical or validity edits, the financial institution will be taken through a review of any quality and/or macro quality edits identified. All quality and macro quality edits will be confirmed or corrected via the online HMDA Platform. Required explanations will be made online. An updated file must be uploaded if any corrections are made.
Certification of HMDA LAR
After review and correction of all edits, an authorized representative of the filing institution must certify the completeness and accuracy of the HMDA LAR via the HMDA Platform.
The HMDA Platform will acknowledge the time and date of submission via a summary screen. After filing, a confirmation receipt will be provided.
Resubmission of HMDA Data
If the HMDA data must be resubmitted, the financial institution will be alerted that a report has already been submitted and will be prompted to confirm that they wish to refile. The same process described for a submission will be followed for a resubmission.
The CFPB plans to provide an online geocoding tool that will allow geocoding of a single address or a batch of addresses. This will be a welcome tool for many institutions.
Information regarding the HMDA Platform can be located at this CFPB link, which includes a link to the Technology Preview.
The information explains pipe delimited files and how the format will be utilized for HMDA submissions. For example, blank fields will be indicated by two consecutive pipes “||”, without placing a space between the pipes.
Preparing for Changes
Those who do not use vendor software will have to become familiar with converting a spreadsheet to a pipe delimited text file using the tool that will be provided, and uploading the file to the HMDA Platform.
All HMDA filers will have to allow time to respond to all edits prior to final submission. Under the current process, certain edits are emailed to the financial institution as a pdf file after the HMDA LAR has been submitted. Under the new process, all edits will be processed and acknowledged or corrected online before the final file can be submitted. Time must be allocated to get through that process prior to the final submission. That means no waiting until the last minute because more work will be required prior to submission. Think of the edits you receive by email now; add sufficient time to your process to review that data prior to the final submission. Also, at least for the first time submitting the 2017 data in first quarter 2018, allow additional time for the first submission using the new process.
If you use vendor software, ask how the file preparation and submission process will work. LAR creation using the new process begins 1/1/2017, just over four months from now.