On February 21, 2018, the FFIEC released a revised HMDA: Getting It Right guide (GIR) for Regulation C changes which took effect on January 1, 2018.
The GIR is in the same format as previous guides and it includes the regulation, appendices and commentary in 12 CFR §1002 plus the CFPB tools. The GIR is a handy resource and you’ll find:
- Regulatory and Reporting Reference Chart;
- HMDA Small Entity Compliance Guide;
- Collection and Reporting of Ethnicity and Race;
- 2018 Institutional Coverage Chart; and
- 2018 Transactional Coverage Chart.
It’s important to note the Appendix A shown in the 2018 GIR is not for the 2018 rules but is for the pre‐2018 filing rules.
Appendix I to the Guide, even with its warnings, simplifies the posted signage requirement.
This is likely to be a “living document” based on rumors of potential upcoming rulemaking by the CFPB to reconsider aspects such as the institutional and transactional coverage tests and the rule’s discretionary data points.
Have you successfully implemented HMDA 2018?
Have you checked your implementation?
TCA can help with a variety of HMDA solutions.
Contact us at (800) 934‐7347 or at [email protected].