Credit unions required to file data under the Home Mortgage Disclosure Act (HMDA) for calendar year 2015 (CY2015) activity must submit Loan Application Register (LAR) data to the Federal Reserve Board (FRB) processing center in an acceptable format by March 1, 2016. Credit unions meeting the filing criteria for CY2015 must comply even if they will no longer have to collect HMDA data during CY2016.1
The LAR provides 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 (opens new window). This document:
- Describes options for filing CY2015 HMDA data;
- Provides a link to the HMDA Data Entry Software;
- Discusses FRB processing procedures;
- Explains NCUA’s policy about late submission of required HMDA data; and
- Provides access to resources to assist in filing HMDA data.
Please note transmissions by methods other than Submission via Web or e-mail may be delayed due to FRB security protocols. Also, there is no guarantee that a file submitted by methods other than Submission via Web is in an acceptable format until FRB processes the file.
Submission via Paper Form
Credit unions with 25 or fewer entries on their LAR may report and submit the data in paper form (opens new window). Credit unions with more than 25 entries on their LAR must submit their reports in an automated form, either via Web, E-mail, or diskette/CD-ROM, as discussed on NCUA’s HMDA page within the FFIEC website (opens new window). Detailed information about automated submission is provided in the 2016 File Specifications document (opens new window).
Submission via Web
FRB prefers receiving the LAR data through the Submission via Web option described in greater detail on the FFIEC’s Frequently Asked Questions webpage (opens new window). The Submission via Web option is the most secure and efficient method because it offers a one-step submission process, where users receive confirmation that FRB successfully received the HMDA data in the correct format for processing. To submit via Web, you must use the HMDA Data Entry software discussed below.
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 firstname.lastname@example.org. This option requires you to use the HMDA Data Entry software discussed below and properly encrypt the LAR data file as discussed on the FFIEC’s Frequently Asked Questions webpage (opens new window). To ensure your e-mail data can be successfully read by FRB, you should use the edit check feature of the HMDA Data Entry Software prior to encrypting and submitting your transmission file.
Submission via Diskette/CD-ROM
The diskette or CD-ROM must be formatted for IBM-compatible personal computers and in ASCII format. Zip files will not be accepted. Additional information about formatting, naming the file, and labeling the package sent to FRB are provided in the 2016 File Specifications document.
HMDA Data Entry Software
The HMDA Data Entry Software (opens new window) (v. 2016) is free on the FFIEC website. The software automates the filing of HMDA data and includes editing features to help you verify and analyze the accuracy of your data. You may submit the data file created using this software to FRB using Submission via Web, encrypted for submission via Internet e-mail, or exported onto a diskette/CD-ROM for mailing. However, there is no guarantee that a file submitted via e-mail, diskette/CD-ROM, or paper form is in an acceptable format until FRB processes the file, as noted above.
Confirmation of Filing and Processing
Data is considered to be successfully received and processed once FRB has uploaded your data (or inputted your data, if sent in paper form) onto its data processing system. When FRB has successfully uploaded (or inputted) your data, FRB will confirm receipt and processing of the file by e-mailing an Edit Report on official FRB letterhead. The Edit Report may list potential data errors. You should receive the Edit Report within ten business days of submitting your data. You should retain a dated copy of the Edit Report with your credit union’s records.
If your credit union does not receive an Edit Report from FRB within ten business days of submitting your data, it is your responsibility to follow up by contacting FRB by e-mail at email@example.com. In the subject heading of the e-mail type ‘Outstanding Edit Report’ and your institution's HMDA reporting ID, agency code and state location. If you do not follow up to receive an Edit Report, your credit union may appear on a delinquent filers list.
Credit unions submitting their data by e-mail will receive an e-mail message from FRB to confirm receipt of the submission. You should contact FRB if you do not receive a timely confirmation of receipt. However, it is important not to confuse the confirmation that FRB received your submission with the Edit Report to document that FRB successfully loaded your data onto its data processing system. The Edit Report is your only confirmation that FRB has received your data in an acceptable format, and will be sent to you regardless of how you filed.
NCUA Policy Concerning Delinquent Filings
NCUA expects every credit union required to report 2015 HMDA data to provide a readable transmission file in an acceptable format to FRB by the March 1, 2016, deadline. After March 1, FRB will provide a list of delinquent filers to NCUA.
Credit unions appearing on FRB’s delinquent filers list could become subject to civil money penalty assessments.
The HMDA (opens new window) page on the FFIEC website is 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. In addition, the website provides access to many other resources, including:
- A Frequently Asked Questions section;
- HMDA Edit information to help ensure data validity, accuracy, and integrity;
- Informational Guide Letters addressing specific HMDA issues, including geographic changes in the FFIEC Census Files;
- FFIEC Census and Demographic Data; and
- Newsletters discussing reporting information.
Questions concerning HMDA software, data receipt confirmations, data edits, and other issues related to submission of HMDA data can be sent to FRB by e-mail at firstname.lastname@example.org. Given the increased volume of inquiries between January and May, FRB advises its response time could exceed two business days.
If you have questions, please contact NCUA’s Office of Consumer Protection at (703) 518-1140 or at ComplianceMail@ncua.gov, or contact your regional office or state supervisory authority.
1 Examples of events causing a credit union previously required to submit HMDA data to become exempt include relocation outside a metropolitan area or a decrease in total assets below the minimum threshold.