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As HMDA 2018 creeps closer, financial institutions are racing against the clock to ensure they are in compliance. But before the new data requirements go live, the first question is: What about 2017 submissions?

We know the CFPB will be receiving the data directly for the first time, but few have seen the new portal live and in action, and many are still seeking to understand exactly how it will work. To help with the process, the CFPB held a live demonstration at their headquarters in Washington, DC to showcase the upcoming HMDA platform, answer questions about its features, and obtain feedback and suggestions.

Read on for the top ten questions the industry vendors wanted to know about the new platform, and what the CFPB developers had to say about it:

  1. What is the current status of the live platform and when will it be made available to end users?

    The 2017 HMDA Platform Beta is complete. CFPB developers have finished a minimum viable product that is migrated and deployed into the final production environment. A select group of user testers reviewed this version of the software and modifications are being made based on their feedback. The predominate software design lifecycle includes updates, such as small tweaks to coloring and language, approximately every two weeks. The intent is to publish the platform for widespread use this quarter and allow end users approximately two months of testing time before its final release in January 2018.
  2. The new submission portal now requires a pipe delimited format.  When an invalid file format is uploaded to the portal, a message indicating there were errors found is displayed. Does the system review the file for all formatting errors or fail at the first error it finds? 

    The error-check will run through the entire file, identifying all errors without stopping. In addition to a message indicating the existence of formatting errors, a list of individual errors will be displayed, showing every formatting error across the full scope of the file. 
  3. The portal will progressively walk users through an edit review process in which each category of edits must be reviewed.  Are all edit checks completed on the file immediately following upload, or will there be progressive processing of edits as a user navigates through the review screens?  

    Once a valid file format is uploaded to the platform, the edit checks in their entirety are run on the file. While the workflow requires users to review edit checks in a progressive order, the full processing is completed on the server side at the front end and will not require reprocessing between each step. The CFPB noted that 98% of filers are working with submission files containing less than 10,000 records and the anticipated user experience will require a one to five second processing time.
  4. Will a user be able to append data to the previous file to progressively edit check and build a submission file?  Will the edit check results be available to export for review purposes?

    Users will not be able to utilize an append function within the platform. Any time a new file is uploaded, it is processed as a separate submission file and cannot be combined with previous uploads. If an institution is accustomed to building a submission file with appended data, they will need to construct a combined file prior to upload, perhaps leveraging a consolidator vendor or combined data warehouse, or manually combining their data sources. The edit check report is exportable, which users can leverage to correct any data requiring updates based on the results.
  5. How many times can the final submission process be repeated? Will it overwrite previous results?

    A financial institution can complete as many final LAR submissions as they choose and the process can be repeated as many times as needed. The system does not overwrite the previous submission files however the most recent version is considered to be the institution’s final submission.
  6. What happens to the data that’s uploaded but not submitted?

    Uploaded data that has not been submitted will not be made available to the regulators.  While the pending data is encrypted and retained on the servers, it is never directly submitted to the regulator until the final submission process is completed.
  7. Who can obtain credentials to log in to the platform on behalf of a financial institution? Are there permission levels available to distinguish who is authorized to complete a final submission?

    The platform is preloaded with domain names for institutions that previously filed HMDA. Any employee with a domain name belonging to the specific financial institution can register for login credentials. If a financial institution’s domain is not yet recognized by the portal, a user will be directed to HMDA Help for further assistance in setting up an account.  

    Currently, there are no user level permissions or controls within the platform. Any user who registers with the financial institution has the ability to complete a final submission.  The CFPB was adamant that this process management remain the responsibility of the financial institution. The current submission process similarly accepts submissions from uncontrolled sources and the new portal is no less controlled than current practices. 

    During the demonstration, the CFPB noted that a final submission confirmation would be emailed to the individual user completing the submission. Based on feedback from audience members, the CFPB is considering copying emails to a specified user for each institution to track total submissions.
  8. Will uploaded or submitted data be recoverable to the institution and is there a plan for a data purge?

    While the CFPB had not considered a need for data recovery to the financial institution, it noted that data is currently not able to be downloaded by a user following its upload to the portal. They are developing a plan for data purging, but in the meantime, a financial institution cannot erase information.
  9. Many financial institutions tend to delay submission until the final days preceding submission deadline. Has the CFPB done any load testing in anticipation of increased volume in these last few days? Are there any contingency plans should the portal fail during this time?

    The CFPB is confident in the portal’s ability to sufficiently handle high volume data loading. They acknowledged researching timelines of files and were aware of the concentration of submissions near the deadline. They reiterated their confidence that no contingency plan would be needed and the platform would perform efficiently for all users. 

  10. The latest platform is specific to the 2017 submission requirements and is not designed to accept 2018 formatted data or run the 2018 edit checks. What is the major difference between the 2017 and 2018 HMDA platforms? And when will the 2018 platform be made available?

    While the backend of the 2018 platform will be radically different in order to accommodate the expanded data requirements and new edit checks, the user experience will largely remain unchanged. The 2018 platform is targeted for a second quarter release, or beginning of next year’s third quarter.

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