Compliance Center: CFPB Releases Additional Resources to Help With HMDA Rule Changes

The Consumer Financial Protection Bureau (CFPB) recently released online resources to assist credit unions to comply with the implementation of the changes to the Home Mortgage Disclosure Act (HMDA).

The HMDA implementation page includes a number of resources credit unions can utilize, including:

  • HMDA final rule
  • HMDA executive summary – An overview of the changes to the HMDA rule issued on October 15, 2015
  • HMDA key dates timeline – One page overview of the effective dates for different elements of the rule
  • HMDA Compliance Guide – A plain-language guide to the new rule which makes the content more accessible for industry constituents, especially smaller businesses with limited legal and compliance staff
  • Reporting “Not Applicable” – A reference tool on when to report data as not applicable
  • Summary of reportable date – A reference tool for HMDA data required to be collected, recorded, and reported
  • HMDA Institutional coverage chart – Does the rule apply to your institution?

The page also contains a like to the Resources for HMDA filers page.  For 2017 or earlier, the FFIEC Website will provide information for HMDA data submission.  For 2018 or later the data will be sent using the instructions for electronic filing.  At this point, the HMDA: Filing Instruction Guide (“FIG”) is not available, but will be provided in the future.

Compliance Question of the Week

What documentation is required in order to open a conservatorship or guardianship account?         

For this type of account, it is best to have the court document detailing that a conservatorship/guardian account should be opened and who the designated conservator/guardian is.  Once that document (for example, Letter of Guardianship) is obtained, you will need to ensure that the guardian has proper identification. In most cases, the tax ID for the account will be that of the person for whom the guardian is appointed, that that person should not have access to the account.  This means that the guardian or conservator is the only person who can operate on the account.

Related Links:

Legal Briefs

National Credit Union Administration (NCUA)

The NCUA announced that the credit union system has seen strong loan growth during the third-quarter.

The video from NCUA Chairman Matz’s open forum is now available online. The open forum covered topics including the proposed MBL rule, cybersecurity, and the modernization of the field-of-membership rule.

The NCUA announced that it has posted new Share Insurance Videos to its YouTube channel. The videos cover topics such as share insurance, how to use the estimator, and account ownership types.

Consumer Financial Protection Bureau (CFPB)

The CFPB released its 2015 annual report from its Ombudsman’s Office.

The CFPB has released its Small Entity Compliance Guide for the new HMDA requirements.

The CFPB released a report detailing how the CARD Act has helped protect consumers avoid deceptive practices. The report did contain some areas of concern, including deferred-interest programs, subprime credit cost, rewards programs, debt collection practices, and credit card agreements that the bureau states are too long and complex for consumers.

CFPB Director Cordray delivered prepared remarks at the Consumer Federation of America. Cordray’s remarks focused on the credit card market, the positive impact that the CARD Act has had for consumers, and the risks that still remain.

Federal Reserve Board (FRB)

The FRB announced approval of a final rule that details the Board’s procedures for emergency lending under the Federal Reserve Act.

The FRB announced that the Beige Book has been updated.

FRB Chair Yellen delivered a speech at the Economic Club of Washington. In the speech, Yellen discussed the strength of the economy and the future outlook for the federal funds rate.

The FRB released its December issue of FedFocus.

Office of the Comptroller of the Currency (OCC)

OCC Comptroller Curry delivered remarks at the RMA Annual Risk Management Conference. Curry’s remarks focused largely on credit risk and how the concern over proper credit risk management is growing.

The OCC issued Bulletin 2015-48 which updates its previous guidance on its risk assessment system.

Financial Action Task Force (FATF)

The FATF released a report detailing how money laundering can occur through the physical transportation of cash. The report identifies the challenges for law enforcement and provides red flag indicators of money laundering through this method.

U.S. Treasury (Treasury)

Secretary of the Treasury Lew delivered remarks at the 2015 Financial Inclusion Forum. Lew’s remarks focused on the limited access to financial services for many Americans and encouraged the participants of the forum to develop ways to encourage access and reduce barriers to financial services.

Federal Financial Institutions Examination Council (FFIEC)

The FFIEC released a statement regarding the agency’s decision to defer the effective date of specific Call Report revisions scheduled to take effect on December 31, 2015 to March 31, 2016.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of December 01, 2015. The last update prior to this was November 25, 2015.

Questions? Contact the Compliance Hotline: 1.800.546.4465,

Posted in Compliance News.