The Office of the Comptroller of the Currency (OCC) issued a bulletin on Tuesday to publicize key fields—which examiners will use to validate the accuracy and reliability of home mortgage loan data collected.
These key fields, which are intended for national banks, federal savings associations, and insured federal branches and agencies of foreign banks, will establish beginning in 2018, pursuant to the Home Mortgage Disclosure Act (HMDA) rule issued October 15, 2015.
According to the release, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the OCC issued “similar guidance designating the same key fields for these purposes.”
In response, Keith A. Noreika, Acting Comptroller of the Currency, said he commends the hard work of the staffs of the OCC and the other federal banking agencies.
“The action the agencies take today will support the efficient and effective evaluation of financial institutions’ compliance with the requirements of HMDA,” Noreika said in a statement released Tuesday.
Noreika continued, “In my conversations with OCC examiners and community banks across the country, I have heard how HMDA data reporting can create an unnecessary burden, especially for small community banks, when they are required to resubmit their entire HMDA reports simply because of a few minor errors.”
Additionally, Noreika added that it has become clear to him that examiners need discretion to exercise judgment to ensure corrections of errors and proper reporting of HMDA data, “without imposing the needless burden involved in a full resubmission.”
In an effort to establish clarity, the OCC’s bulletin makes it clear to OCC examiners that they have the discretion and should exercise judgment in their supervisory actions to ensure the accurate collection of HMDA data—without requiring burdensome resubmissions, according to the OCC.
The purpose of HDMA, which is implemented by Regulation C (12 CFR 1003), is to require certain financial institutions to collect, record, and report information about mortgage lending activity.
Therefore, HMDA amendments attempt to ensure compliance with the HMDA’s requirements, traditionally the FRB, the FDIC, and the OCC have identified and focused examination-related testing of HMDA data on certain agency-designated key fields. According to the OCC, the key fields are those fields considered to be “most important to ensuring the integrity of analyses of overall HMDA data.”
To view the full bulletin, click here.