The CFPB has not yet finalized a rule implementing the new HMDA fields required by the Dodd-Frank Act, and we do not believe that any financial institutions will be required to report on the new data fields for this year. The Dodd-Frank Act added several new HMDA data fields (listed below):
- Age
- Application channel (i.e., broker)
- Credit score
- Loan originator identifier (SAFE Act)
- Loan term
- Negative amortization
- Prepayment penalty term
- Property’s parcel number
- Property value
- Rate spread for all loans
- Term of introductory rate period
- Total origination points and fees
- Universal loan identifier
However, those data fields won’t go into effect until after the CFPB issues a final rule adding these fields to Regulation C. The CFPB has issued a proposed rule implementing the data fields required by Dodd-Frank, as well as several data fields beyond the fields required by statute. Even after the CFPB issues a final rule, financial institutions will not be required to report the new data until the first full year after nine months pass from the date of the final rule. In other words, the new data fields won’t go into effect until the first January 1 after the end of the nine month period beginning on the date that the CFPB issues a final rule. 12 USC 2803(n). If the CFPB issues a final rule by March of 2015, the earliest possible effective date is January 1, 2016.