On March 26, 2020, the CFPB issued a statement to inform its supervised financial institutions that it does not intend to cite in an examination or initiate an enforcement action for failure to report the quarterly HMDA data for those institutions subject to the new 2018 HMDA quarterly reporting requirements. Financial institutions that report for the preceding calendar year at least 60,000 covered loans and applications (excluding purchased loans) must report their HMDA data quarterly (except for the fourth quarter) in addition to annually. The first quarterly submissions in 2020 was originally due by May 30, 2020.

The Board of Governors of the Federal Reserve (FRB) also announced in CA 20-6 that it will take the same approach in order to provide its supervised financial institutions with flexibility, reduce administrative burden, and allow the institution to focus its time and attention on serving its customers. At a later date, the FRB will provide information as to how and when it expects its supervised institutions to resume quarterly HMDA data submissions. In the meantime, institutions should continue collecting and recording HMDA data in anticipation of making annual data submissions.


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