Bureau of Consumer Financial Protection releases FIG for 2019 HMDA
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The Bureau of Consumer Financial Protection, formally known as the Consumer Financial Protection Bureau, released its 2019 Filing Instructions Guide for the Home Mortgage Disclosure Act for data collected in 2019 and reported in 2020. This guide is useful for compliance officers, information technology support staff, and staff members, who collect, prepare and submit HMDA data. Financial institutions that report HMDA data should review the Filing Instructions Guide (FIG) to understand updates to the instructions, despite no significant changes to the required data or to the submission process for data. Besides numerous edit revisions, there are other changes, including instructions for reporting negative debt-to-income ratios, updated examples for application date and actions taken, updated instructions for reporting credit scores, adding seven Automated Underwriting System (AUS) options, updated AUS values and guidance on reporting AUS results. The Bureau also included an updated table to show the 2019 edit revisions in the FIG. The FIG also provides file specification information, including valid values, formatting a financial institution’s Loan Application Register (LAR), and instructions on completing each field in the LAR, accounting for the recently implemented partial exemption for certain entities. The FIG also states going forward that the process for validating the edit report has changed. All financial institutions must address all edits prior to submitting their HMDA data to the BCFP. The new FIG is effective for loan application registers required to be filed by March 1, 2020.