Submission of 2018 Home Mortgage Disclosure Act Data

Credit unions located in metropolitan areas that engage in certain types and volume of residential mortgage lending, and that had assets exceeding $45 million as of December 31, 2017, must file a report this year on mortgage loan applications on which they took action during 2018.  The filing is required under the Home Mortgage Disclosure Act (HMDA), as implemented by the Consumer Financial Protection Bureau’s Regulation C.[1]

To determine if your credit union must submit HMDA data for calendar year 2018 activity, please review the 2018 HMDA Institutional Coverage Chart.

2019 Submission Process for Data Collected in 2018

The deadline for filing

Credit unions subject to HMDA requirements in calendar year 2018 must submit loan/application register (LAR) data to the Consumer Financial Protection Bureau (CFPB) by March 1, 2019.                                                                      

The way you submit your HMDA data

Credit unions must submit their HMDA data using a web interface referred to as the HMDA Platform.  No other submission methods are permitted.  Credit unions will use the HMDA Platform to upload their LAR data, review and make edits, certify the accuracy and completeness of the data, and submit data for the filing year.

The HMDA Platform will walk you through the loan/application register filing process.  Credit unions should use a modern web browser, such as the latest version of Google Chrome, Mozilla Firefox, Internet Explorer 11 or Microsoft Edge. 

The LAR format you use to submit your HMDA data

Credit unions must submit data collected in a pipe delimited text file (.txt).  A LAR Formatting Tool has been developed to help format certain data into a pipe delimited text file.  The LAR Formatting Tool may be especially helpful for credit unions with small volumes of reported loans that do not use vendor or other software to prepare their HMDA data for submission.

The process by which you validate the edit report

Credit unions must address all edits prior to submitting their HMDA data.  The edit report, which flags potential errors, will be web-based:

• Edit reports will not be e-mailed to credit unions in PDF format.  Instead, the CFPB edit reports will be viewed directly in the HMDA platform.  You can also download the reports.
• Responses to the edits cannot be faxed or e-mailed to the CFPB.  The HMDA Platform will guide credit unions through the process of addressing edits.

The Officer Certification process

As part of the submission process, an authorized representative of your credit union with knowledge of the data submitted must certify the accuracy and completeness of the data submitted.  Credit unions cannot fax or e-mail the signed certification.

Additional resources, including the Filing Instructions Guide for HMDA data collected in 2018, can be found on the Resources for HMDA filers page on the CFPB’s website.

You should direct technical questions about reporting HMDA data collected in or after 2018 hmdahelp@cfpb.gov.

NCUA Policy Concerning Delinquent Filings

NCUA expects every credit union required to report 2018 HMDA data to submit its file to the CFPB by the March 1, 2019, deadline.  Credit unions appearing on a delinquent filers list could become subject to civil money penalty assessments.

If you have questions about this information, please contact NCUA’s Office of Consumer Financial Protection at (703) 518-1140 or at ComplianceMail@ncua.gov, or contact your regional office or state supervisory authority.