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Regulatory Alert: Submission of 2012 Home Mortgage Disclosure Act (HMDA) Data

REGULATORY ALERT

NATIONAL CREDIT UNION ADMINISTRATION
1775 Duke Street, Alexandria, VA 22314

DATE: January 2013 LETTER No.: 13-RA-02
TO: Federally Insured Credit Unions Over $41 Million in Assets
SUBJ: Submission of 2012 Home Mortgage Disclosure Act (HMDA) Data
​Dear Board of Directors and Chief Executive Officer:

Credit unions located in metropolitan areas that engage in certain types of residential mortgage lending and that had assets exceeding $41 million as of December 31, 2011, must file a report regarding mortgage loan applications received during 2012.  The filing is part of the compliance with the Consumer Financial Protection Bureau’s Regulation C, which implements HMDA.1

Credit unions that were subject to HMDA requirements in calendar year 2012 (CY2012) must submit loan/application register (LAR) data to the Federal Reserve Board (FRB) by March 1, 2013.

To determine if your credit union must submit HMDA data for CY2012 activity, please review Regulatory Alert 12-RA-02, “Home Mortgage Disclosure Act Data Collection Requirements for Calendar Year 2012” (March 2012). It is available at http://www.ncua.gov/Legal/Pages/RA2012-02.aspx.

The purpose of this Regulatory Alert is to:

  • Describe your options for filing CY2012 HMDA data; and
  • Inform you of NCUA’s policy concerning late submission of required HMDA data.
Filing Deadline for 2012 HMDA Data

Credit unions subject to HMDA requirements for CY2012 activity must submit LAR data to the FRB processing center by March 1, 2013.  Credit unions meeting the filing criteria for CY2012 must comply even if they will no longer have to collect HMDA data during CY2013.2

The LAR requires data about the mortgage loan applications processed during the reporting year.  Additional information about the LAR filing requirements is available on the Federal Financial Institutions Examination Council (FFIEC) website at http://www.ffiec.gov/hmda/default.htm.
 
Filing Options

Credit unions with 25 or fewer entries on their LAR may report and submit the data in paper form. However, credit unions with more than 25 entries on their LAR must submit their reports in an automated, machine-readable form under one of the methods discussed at http://www.ffiec.gov/hmda/contactNCUA.htm.

Submission via Web
The FRB prefers receiving the LAR data through the “Submission via Web” option described in greater detail at http://www.ffiec.gov/hmda/faqtech.htm#srs2. This option is the most secure and efficient method because it offers a one-step submission process, where users receive confirmation that the FRB successfully received the HMDA data.

Submission via E-mail
If you do not use the “Submission via Web” option, you also have the option of submitting automated LAR data by e-mail to hmdasub@frb.gov.  This option requires proper encryption of the LAR data file using the FFIEC Data Entry Software encryption utility before transmission. The encryption process requires installing the free Internet submission software on the FFIEC website at http://www.ffiec.gov/software/default.aspx.  To ensure your e-mail data can be successfully read by the FRB, you should use the edit check feature of the HMDA Data Entry Software prior to encrypting and submitting your transmission file.

The HMDA Data Entry Software (Version 2012) is also free on the FFIEC website at http://www.ffiec.gov/hmda/softinfo.htm. The software automates the filing of your HMDA data and includes editing features to help you verify and analyze the accuracy of the data. The data file created using this software can be submitted to the FRB using “Submission via Web,” encrypted for submission via Internet e-mail, or exported onto a diskette/CD-ROM for mailing. Please note transmissions by methods other than “Submission via Web” or e-mail may be delayed due to FRB security protocols.

Confirmation of Filing

Data is considered to be successfully received once the FRB has uploaded your data onto its mainframe computer. When the FRB has successfully uploaded your data, the FRB will confirm receipt of the file by faxing or e-mailing an Edit Report that lists potential data errors.  You should retain a dated copy of the Edit Report with your credit union’s records. The following general time frames apply:

  • If you sent your submission using the “Submission via Web” or Internet e-mail option, you should receive an Edit Report by fax within a week of transmitting your report.
  • If you sent your submission via diskette or CD-ROM, you should receive an Edit Report via fax within two weeks of mailing your report.
Credit unions submitting their data by e-mail will receive an e-mail message from the FRB that confirms receipt of the submission. It is important not to confuse the confirmation that the FRB has received your submission with the Edit Report that documents the FRB successfully loaded your data onto its mainframe computer. The FRB only considers your data as being received when it issues the Edit Report.
 
If your credit union does not receive an Edit Report from the FRB, it is your responsibility to follow up.

In the recent past, several credit unions neglected to contact the FRB when they did not receive a timely confirmation of receipt.  Several others neglected to follow up when they did not receive a list of potential data errors after initially receiving a confirmation of receipt.  As a result, those credit unions were unaware that their LAR data was not successfully loaded onto the FRB’s mainframe computer until appearing on a delinquent filer list.

NCUA Policy Concerning Delinquent Filings

NCUA expects every credit union that is required to report 2012 HMDA data to provide a readable transmission file to the FRB by the March 1, 2013 deadline.  Following March 1, the FRB will provide a list of delinquent filers to NCUA.

Credit unions appearing on the FRB’s delinquent filers list could become subject to civil money penalty assessments.

Other Resources

The FFIEC maintains a website (http://www.ffiec.gov/hmda/default.htm) designed to assist financial institutions with HMDA compliance.  Included on the site is a comprehensive publication entitled A Guide to HMDA Reporting: Getting it Right! The guide provides information about the history of HMDA, data reporting requirements, LAR completion, geocoding tools, and disclosure requirements.

Questions concerning HMDA software, data receipt confirmations, data edits, and other issues related to submission of HMDA data can be sent to the FRB by e-mail at hmdahelp@frb.gov, or you may call the HMDA Assistance Line at (202) 452-2016. Please use only one method of communication when you have questions. Given the increased volume of inquiries between January and May, the FRB advises its response time could exceed five business days.

NCUA will host a free webinar about HMDA and LARs.  Entitled “HMDA: Accuracy and Timeliness,” the webinar will start January 24, 2013, at 2 p.m. EST.  Registration for this free webinar is now open at
http://event.on24.com/r.htm?e=557813&s=1&k=738E204D1BFB48A4DB10E0852E82291C.

If you have questions about completing the LAR, please contact the NCUA Office of Consumer
Protection,3 your regional office, or state supervisory authority.
Sincerely,

     /s/

Debbie Matz
Chairman


1 The Dodd-Frank Wall Street Reform and Consumer Protection Act transferred rulemaking authority for HMDA to the Consumer Financial Protection Bureau (CFPB), effective July 21, 2011. Regulation C was recodified as 12 CFR Part 1003, effective December 19, 2011.
2 Examples of events causing a credit union previously required to submit HMDA data to become exempt include relocation from a metropolitan area or a decrease in total assets below the minimum threshold.
3 You can reach NCUA’s Office of Consumer Protection at 703-518-1140 or OCPMail@ncua.gov