On February 18, the CFPB and the Federal Financial Institutions Examination Council (FFIEC) published new “File Specifications” for data to be collected pursuant to the Home Mortgage Disclosure Act (HMDA) and its implementing regulation, Regulation C, in 2017 and 2018. These File Specifications follow the CFPB’s October 15, 2015, final rule (the “Rule”) amending Regulation C, published in the Federal Register on November 10. As contemplated by the Rule, the new File Specifications make changes to the format and method in which HMDA data must be submitted. More importantly, the 2018 File Specifications show the number of individual data fields that will ultimately be necessary to implement the Rule’s new collection requirements—110. Yes, that is right, 110.
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