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As financial institutions scramble to maintain operations and aid customers and members as COVID-19 continues to spread, the Consumer Financial Protection Bureau (CFPB) announced it’s giving FIs some breathing room when it comes to Home Mortgage Disclosure Act (HMDA) data collection.

Recognizing that FIs are hyper focused on helping customers, the CFPB said FIs don’t have to turn in quarterly HMDA data until further notice. (It would have been due May 30.)

During this time, the CFPB says that failure to report HMDA data quarterly won’t result in a citation during an exam or an enforcement action.

The CFPB also said it would be flexible with exam timing and activities to “minimize disruption and burden.” The agency will consider the challenges FIs are facing due to COVID-19 and good-faith-efforts to help customers during the pandemic.

“As consumers seek temporary relief from lenders, the pandemic is impacting the operations of financial companies that are eager to help their customers during this unprecedented time,” said CFPB Director Kathy Kraninger. “Our actions today are temporary and targeted to support consumers by allowing financial companies to focus their resources on assisting consumers.”

The CFPB also delayed data collection for annual submissions related to agreements between credit card issuers and institutions of higher education; quarterly submission of consumer credit card agreements; collection of certain credit card price and availability information; and submission of prepaid account agreements and related information. Two FI surveys were also postponed.

What Does the HMDA Data Postponement Mean for Your FI?

FIs should feel at least a small burden lifted with the postponement of HMDA data reporting, but it’s not a total reprieve. Action is still needed.

Make sure your FI continues to:

  • Collect and record HMDA data. Don’t let your data collection slide. The CFPB still plans to collect annual data. If you save data collection for the last minute, it will be a huge task. (The CFPB will announce when it plans to resume quarterly collections.)

  • Analyze HMDA data. Data collection may be suspended, but Fair Lending laws remain in effect. Make sure you continue to analyze your HMDA data to uncover and address disparities. You don’t want to come out of the crisis with a major fair lending problem.

  • Keep track of how the FI is aiding borrowers. The CFPB says examiners will look at the good-faith efforts of mortgage lenders to help borrowers. Make sure your FI is tracking its programs and the number of customers helped.

As always, Ncontracts is here to help you manage Fair Lending, risk, and compliance.

 

Kimberly Boatwright, CRCM, CAMS

Kimberly Boatwright, CRCM, CAMS