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With the filing period for data collected under the Home Mortgage Disclosure Act (HMDA) in 2018 underway, NAFCU's compliance team is working to provide credit unions with the guidance and resources necessary to correctly submit their data.

The filing period for HMDA data collected in 2018 officially opened Jan. 1. This year, institutions are required to have a legal entity identifier (LEI) for Loan/Application Registers (LARs) filed, rather than the previous institutional identification numbers.

A NAFCU Compliance Blog post includes resources on entities offering LEI services, the cost to obtain an LEI and their length of validation.

The association has also updated its S. 2155 summary chart, which includes a note about the bureau's final rule to implement and clarify a provision that exempts certain credit unions from collecting and reporting on certain data points added to HMDA by the Dodd-Frank Act. The bureau has updated its Small Entity Compliance Guide to incorporate S. 2155 changes as well.

The bureau in October released its filing instructions for HMDA data collected this year and reported on in 2020. A new resource from the NCUA features the bureau's reference chart that is intended to be used as a reference tool for those data points required to be collected, recorded and reported under HMDA in 2019.

NAFCU continues to seek more guidance on HMDA to ensure credit unions are compliant with the law.