DIVISION OF CONSUMER AND

COMMUNITY AFFAIRS

CA 20-1

February 27, 2020

TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS 

SECTIONS:

Applicability to Community Banking Organizations: This guidance applies to all institutions 

supervised by the Federal Reserve, including those with total consolidated assets of $10 billion 

or less.

SUBJECT: Revised “A Guide to HMDA Reporting: Getting It Right!”

The Task Force on Consumer Compliance of the Federal Financial Institutions 

Examination Council recently developed a revised version of “A Guide to HMDA Reporting: 

Getting It Right!” (Guide). The updated Guide is intended to assist financial institutions in 

complying with the Home Mortgage Disclosure Act (HMDA) 1 as implemented by the Consumer 

Financial Protection Bureau’s (CFPB) Regulation C.2 This Guide applies to HMDA data that 

financial institutions are required to collect beginning on January 1, 2020 and must submit by 

March 1, 2021. The Guide provides helpful background information and an easy-to-use summary 

of certain key requirements, including those relating to institutional coverage, transactional 

coverage, and data collection, reporting, and disclosure requirements. 

This edition of the Guide incorporates amendments made to HMDA by the Dodd-Frank 

Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)3 and the Economic Growth, 

Regulatory Relief, and Consumer Protection Act (EGRRCPA).4 The Dodd-Frank Act amended 

HMDA, transferred rulewriting authority to the CFPB, and expanded the scope of information 

that must be collected, reported, and disclosed under HMDA, among other changes. 

In October 2015, the CFPB issued the 2015 HMDA Rule implementing the Dodd-Frank

Act amendments to Regulation C.5 The 2015 HMDA Rule modified the types of institutions and 

 1 12 U.S.C. 2801 et seq.

2 12 C.F.R. Part 1003.

3 Public Law No. 111-203, 124 Stat. 1376, 2097-2101 (2010).

4 Public Law No. 115-174, 132 Stat. 1296 (2018). The President signed the EGRRCPA into law on May 24, 2018.

5 80 FR 66128 (October 28, 2015) (2015 HMDA Rule).
2

transactions subject to Regulation C, the types of data that institutions are required to collect, and 

the processes for reporting and disclosing the required data. On August 24, 2017, the CFPB 

issued a 2017 HMDA Rule to further amend Regulation C to make technical corrections and 

clarify certain requirements adopted by the 2015 HMDA Rule.6

The EGRRCPA amended HMDA by adding partial exemptions from HMDA’s 

requirements for certain transactions made by certain insured depository institutions and insured 

credit unions. On August 31, 2018, the CFPB issued a 2018 HMDA Rule to implement and 

clarify changes made by the EGRRCPA.7 On October 10, 2019, the CFPB issued the 2019 

HMDA Rule to extend the temporary threshold for reporting data about open end lines of credit 

and implement the partial exemptions created by the EGRRCPA.8

If you have any questions, please contact Anh Quach, Senior Consumer Financial 

Services Analyst, at (202) 452-3364; or Meghan Karellas, Manager, at (202) 736-5536. In 

addition, questions may be sent via the Board’s public website.9 

Sincerely, 

Carol A. Evans

Associate Director

Attachment:

• Revised “A Guide to HMDA Reporting: Getting It Right!”

Cross-references:

• CA 19-5 “Revised Home Mortgage Disclosure Act Examination Procedures” (April 1, 

2019)

• CA 18-9 “Designated Home Mortgage Disclosure Act Key Data Fields” (December 7, 

2018)

• CA 18-6 “Statement on the Implementation of the Economic Growth, Regulatory Relief, 

and Consumer Protection Act Amendments to the Home Mortgage Disclosure Act” (July 

5, 2018)

• CA 17-4 “Expectations for Supervised Institutions Regarding Amended Regulation C” 

(December 21, 2017)

• CA 17-2 “Revised Interagency Home Mortgage Disclosure Act Sampling, Verification, 

and Resubmission Procedures” (August 22, 2017)

 6 82 FR 43088 (September 13, 2017) (2017 HMDA Rule).

7 83 FR 45325 (Sept. 7, 2018) (2018 HMDA Rule).

8 84 FR 57946 (Oct. 29, 2019) (2019 HMDA Rule).

9 See http://www.federalreserve.gov/apps/contactus/feedback.aspx.