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Financial Institution Letter

Home Mortgage Disclosure Act:

Statement on Institutions' Good Faith Compliance Efforts

Summary:

The FDIC is issuing a statement regarding the evaluation of financial institutions' compliance with the Home Mortgage Disclosure Act (HMDA), implemented by Regulation C. Specifically, for HMDA data collected in 2018 and reported in 2019, the FDIC does not intend to require data resubmission unless data errors are material. In addition, the FDIC does not intend to assess penalties with respect to errors in data collected in 2018 and reported in 2019. Through this supervisory approach, FDIC examination staff will give credit to institutions' good faith compliance efforts, and the approach will help institutions identify compliance weaknesses.

Statement of Applicability to Institutions Under $1 Billion in Total Assets: This Financial Institution Letter applies to all FDIC-supervised institutions.

Highlights:

  • HMDA, implemented by Regulation C, requires certain financial institutions to collect, report, and disclose information about their mortgage lending activity.
  • In 2018, FDIC examination staff will begin evaluating financial institutions' compliance with the Consumer Financial Protection Bureau's (CFPB) October 15, 2015, and August 24, 2017, amendments to Regulation C.
  • Recognizing the impending January 1, 2018, effective date of CFPB's amendments to Regulation C, and the significant systems and operational challenges needed to adjust to the revised regulation, the FDIC is issuing a Statement on Financial Institutions' Good Faith HMDA Compliance Efforts.
  • If you have any questions, please contact your local FDIC field or regional office.

Distribution:

  • FDIC-Supervised Institutions

Suggested Routing:

  • Chief Executive Officer
  • Compliance Officer
  • Chief Lending Officer

FDIC Financial Institutions Letters (FILs) may be accessed from the FDIC's website at https://www.fdic.gov/news/financial-institution-letters/2017/

Paper copies may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, E- 1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).

FIL-63-2017
Attachments
Last Updated: December 21, 2017