7 Issues Reported with the New CFPB HMDA Platform and Tools
With the new HMDA rules in effect and the new CFPB HMDA Platform now accepting 2017 submissions, growing pains and hiccups are to be expected. The CFPB recently said that it would not assess penalties for bonafide errors in data collected in 2018 and it recognized that there were significant operational challenges needed to meet the requirements under the rule.
While this is great news, the new CFPB HMDA Platform and tools aren’t without their own issues.
Here are 7 issues compliance officers are facing with the new CFPB HMDA Platform and tools:
1. Fluctuating processing times for HMDA submissions
We previously reported that early feedback indicated smaller submission files (under 500 records) were taking up to an hour to upload, while others reported only minutes. Files with more than 10,000 records were taking four hours to upload, while files with over 30,000 records could take over eight hours!
We have been actively communicating with the CFPB, which has resulted in updates to the submission platform that have significantly reduced the long processing times.
However, upload times are still dependent on many external factors, including the time of day, strain on the system and syntactical edits present in the file.
The longest parts of the process are steps 1 & 2 when the file is uploading and being checked for syntactical and validity edits (see below). If it appears to be frozen, you can log out of the system (or close your browser) and return later to check on the status (no data should be lost).
As always, submit your data early.
2. No third-party API for the CFPB HMDA Platform
The CFPB has not released an API for submissions. This means that compliance software vendors cannot submit data directly to the CFPB, filers must manually log into the website and drag and drop their file to upload it to the HMDA platform. The CFPB could create a more seamless process by releasing an API but for now it remains a manual process.
3. Delay creating a new account
The CFPB platform only allows for authorized institutions to create logins. Past HMDA filers can quickly create logins using their institutions email addresses, however, new filers will have to email firstname.lastname@example.org and provide their institution’s name plus one other identifier (RSSD, tax ID, NMLS ID, etc.). This causes a delay as the new filer’s institution must be manually added to the platform by the CFPB.
If your institution is a first-time HMDA filer, we suggest you create an account now so that you will be ready to file once your data is error free.
4. No controls for logins
Users have reported that anyone can create a login on the CFPB HMDA Platform if their institution’s name is on the list. This can cause a variety of issues. One of the main issues is how to manage who has access from the institution and which account is the official authorized representative to approve the filing.
5. Using the wrong rate spread calculatorPeople have been reporting mixed results when trying to use the new CFPB Rate Spread Calculator. For Final Actions taken between 2010 and 2017 use the old FFIEC Rate Spread Calculator.
6. The CFPB geocoder isn’t ready
The CFPB still hasn’t released its new geocoder tool. While this isn’t exactly a surprise, the CFPB is recommending people continue to use the FFIEC geocoder. The problem with this is the FFIEC geocoder does not allow you to batch geocode and it uses older census tract data, which may lead to accuracy errors down the road.
7. Limited LAR formatting toolIf you are not currently using compliance software, then you may have a hard time formatting your LAR into the appropriate pipe delimited format. The CFPB released a LAR Formatting Tool to help filers format their data into the correct format for submission, but this tool is only intended to be used for small volumes of loans. If you are new to HMDA and do not use compliance software, this may be an issue for you.
Over the years QuestSoft has become an expert in all things HMDA. Our HMDA RELIEF software can reduce your processing and submission time by 90%. HMDA RELIEF allows you to use group edits to fix errors on multiple loans and batch geocode your files within seconds. CLICK HERE to schedule a demo!