By Alexander Smith
The Federal Financial Institutions Examination Council (FFIEC) announced the release of the Beta version of the Home Mortgage Disclosure Act (HMDA) Filing Platform that financial institutions will utilize to report data collected in 2018. The HMDA platform is currently available for financial institutions to use in a test environment to become familiar with the platform, and determine whether their sample Loan Application Register data complies with the reporting requirements set forth in the Filing Instructions Guide for HMDA data.
The Beta version of the HMDA Filing Platform will allow users to upload sample 2018 HMDA data files, validate data submitted, receive a sample submission confirmation, and conclude the filing process. All test data uploaded during the beta period will be removed from the system when the filing period opens in January 2019.
The announcement also notes that in order to use the beta version of the HMDA Filing Platform, financial institutions must have a Legal Entity Identifier (LEI) which uniquely identifies the institution, and that LEI must be recognized by the HMDA Filing Platform in order to create a new account or test data with an existing account.
If your institution has an LEI, and that LEI is not currently recognized by the HMDA Platform, you will need to submit a registration form through the Consumer Financial Protection Bureau website before you can use the platform. If your institution has not registered for an LEI and intends to file HMDA data collected in 2018, visit the Global LEI Foundation for information on obtaining an LEI.
Contact me or another member of Kaufman Rossin’s Risk Advisory Services team to learn more about how these rules may impact your financial institution.