The CFPB said it opened a 60-day comment period to help determine if the changes to its Home Mortgage Disclosure Act Resubmission Guidelines are appropriate for the HMDA data submitted as a result of recent Regulation C changes.
The Regulation C changes took place in October 2015. Specifically, the CFPB is seeking information about which modifications may be appropriate for the data that will be reported under the amendments made to Regulation C that may impact the bureau's Resubmission Guidelines.
Currently, the agency requires financial institutions reporting fewer than 100,000 loans or applications on the HMDA loan/application register to correct and resubmit HMDA data when errors are found in 10% or more of the HMDA LAR sample entries or 5% or more of the sample entries within an individual data field.
In addition, the Resubmission Guidelines instruct financial institutions reporting 100,000 or more entries on the HMDA LAR to correct and resubmit HMDA data when errors are found in 4% or more of the HMDA LAR sample entries, or between 2% and 4% of the sample entries within an individual data field. The Resubmission Guidelines note that resubmission may be required even if sample error rates are below the specified thresholds if the errors lead to an unreliable analysis of the institution's lending.
Among the information sought by the agency is an error percentage threshold for use in determining the need for data resubmission. The CFPB is also asking for input on how to ensure data integrity and compliance with HMDA and Regulation C, as well as on the error percentage threshold calculations.
"The Home Mortgage Disclosure Act is a valuable asset in helping detect trends and problem areas in the nation's mortgage market, and the recent improvements to the rule will foster better understanding of that market," CFPB Director Richard Cordray said in a news release. "With today's request for information we are seeking feedback from stakeholders on how best to ensure the accuracy and reliability of mortgage lending information."
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