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Friday is the deadline for covered institutions to file their first Loan/Application Register (LAR) with the CFPB, which includes the expanded data points required to be collected in 2018 under the Home Mortgage Disclosure Act (HMDA). A NAFCU Compliance Blog post answers some frequently asked questions as credit unions work to comply with the law.

In the blog post, NAFCU Vice President of Regulatory Compliance Brandy Bruyere notes that some credit unions have reported problems with the bureau's platform for submitting HMDA data; NAFCU has reached out to the bureau seeking additional information on the issue.

Bruyere then answers these four questions:

1. If a credit union works with a mortgage CUSO, should the CUSO be collecting and reporting HMDA information? Does it matter if the CUSO does not actually make the decisions or retain the loans that are funded?
2. Our credit union writes business loans that are HMDA reportable. Which data points do we need to report for these loans?
3. If a loan application is incomplete and the applicant does not submit the missing information so that the credit union can make a decision on the loan, is it still HMDA reportable?
4. Are loans for recreational vehicles (RVs) subject to HMDA reporting?

See Bruyere's answers here. Also, NAFCU's compliance team is available to answer additional questions and provides a response within one business day. Contact the compliance team here.

NAFCU has a number of HMDA resources available and continues to seek more guidance on HMDA to ensure credit unions are compliant with the law.