For HMDA data collected in or after 2017, a web-based data submission and edit-check system (the HMDA Platform) is being created to process Home Mortgage Disclosure Act (HMDA) data. It is expected that the HMDA Platform will streamline the HMDA submission process and reduce burden on HMDA filers.
This web page is intended to provide an initial view into the way HMDA filers will interact with the HMDA Platform. Additionally, this web page describes resources that will be available for filers, developers, and the interested public. This web page will be updated on an ongoing basis, to keep stakeholders informed of new developments.
The HMDA Platform will be available online only and will guide filers through the entire filing process, including the review of any edits and the certification of the accuracy and completeness of the loan/application register. A separate Filing Instructions Guide (FIG) describes the file format and other requirements.
The HMDA Platform will require every HMDA filer to register online for login credentials and establish an account prior to using the system.
Once established, a HMDA filer’s account will allow a financial institution to upload its loan/application register, check on which stage it is in the filing process, complete the review and verification steps, and submit the loan/application register.
The CFPB will provide details on the registration process in a future update.
The HMDA Platform will allow the filer to select the appropriate loan/application register from a local or network file system. The newly-uploaded file will supersede any previously uploaded file for which the filer did not complete the submission process.
The HMDA Platform will confirm the upload of the selected loan/application register, check that the file is pipe delimited (see FIG sec 3) and has the correct number of data fields (see FIG sec 3). If the file is not properly formatted, the HMDA Platform will send an error message and require the HMDA filer to correct and refile the loan/application register.
Once the HMDA Platform confirms that the loan/application register is in the correct format, it will check the accuracy and completeness of the loan/application register using the HMDA edits. An interactive process will inform the filer of the current stage of review, any items that need to be addressed, and next steps for completing the HMDA filing. At each stage, any edits identified in the loan/application register will be reported back to the filer.
For data collected in 2017, the edits are listed in Section 4 of the FIG for HMDA data collected in 2017. Edits for data collected in 2018 will be released at a later date.
The HMDA Platform will identify any syntactical or validity edit and the rows in the loan/application register where each edit is triggered. Additionally, a list of the edits identified in the loan/application register will be available for download.
Syntactical and validity edits must all be addressed prior to moving forward with the filing process. If the filer needs to correct any data, the filer must refile the updated loan/application register to the HMDA Platform. The loan/application register will then be rechecked for syntactical and validity edits.
Once the HMDA Platform has confirmed there are no syntactical or validity edits, the filer will be prompted to review any quality and/or macro quality edits that the HMDA Platform identifies in individual rows in the loan/application register, groups of rows, or the entire loan/application register. The filer must either confirm the accuracy or correct all data flagged by the quality edits through the user interface and provide explanations for any macro quality edits. If a filer corrects any data in response to quality and macro edits, the filer must refile the updated loan/application register in the HMDA Platform.
Once all edits have been addressed, the HMDA Platform will require an authorized representative of the filer’s institution to certify the completeness and accuracy of the loan/application register (see FIG section 3.2).
After the filer submits the loan/application register, the HMDA Platform will provide the filer with a summary screen acknowledging the time and date of submission.
In cases where a submission has been completed, the HMDA Platform will alert the filer that the loan/application register for the reporting year has already been filed, and prompt the filer to confirm that they wish to refile their loan/application register.
A HMDA resubmission requires the same edit review and certification by the institution’s authorized representative as an initial submission.
A new online geocoding tool will be provided that identifies the census tract for a single address or batches of addresses. Further information will be forthcoming.
A loan/application register formatting tool will be provided to help filers format their HMDA data into a pipe delimited text file format. This tool may be especially helpful for filers with small volumes of reported loans. Further information will be forthcoming.
The CFPB is committed to developing the programming code for the HMDA Platform in an open way. The HMDA Platform is being actively developed on the site, GitHub.com (see: https://github.com/cfpb/hmda-platform). This provides transparency to the algorithms and methodologies used to parse and validate a HMDA file, as well as the code used to develop the HMDA Platform user interface and related tools for filers. This code is in the public domain and does not impact the privacy or security of the data.
As noted above, the CFPB is developing the HMDA Platform in the open. With the exception of internal server deployment details, the source code will be available to review and use.
While most HMDA filers and interested members of the public will interact with the HMDA Platform primarily through the web, the HMDA Platform is developed with an API-first approach, with a modern architecture intended to be efficient and flexible.
Details of public APIs and other developer resources will be released on the Resources for Filers page on the CFPB website and on GitHub.