HMDA and CRA Submission Tip of the Week

February 10, 2021
The deadline for submitting your 2020 HMDA and CRA data is on March 1, 2021.

In preparation for this year’s HMDA submission, RiskExec recommends that you verify the Rate Spreads on all of your records and confirm that they are correct.

In 2020, there were two instances where the CFPB had an error in the APOR tables on their website. It is important to note that these tables are used to calculate the Rate Spread in your RiskExec HMDA records.  However, the RiskExec system will only maintain the most current set of APOR tables and will automatically update the tables if and when the APOR tables are updated on the CFPB website. 

The RiskExec team has connected with the CFPB on several occasions in an effort to receive guidance on how to handle this situation.  Unfortunately, the CFPB has not offered any clear recommendations on which rates to use for loans that were locked in during the period when the APOR tables were in error.  Therefore, RiskExec recommends that each institution review all of the loans that were locked in or booked on the dates in the ranges listed below. Please evaluate all Rate Spreads in preparation for your institution’s submission.

The first incident occurred during the release of the tables on July 17, 2020, for the APOR Rates for Fixed Rate Loans.  Please see below:

Sign up for news + updates

Expert insights and regulatory updates on RegTech, compliance management, and fair lending.

Questions? Comments?

Contact RiskExec customer support at

Anurag Agarwal, PhD

President, RiskExec

Recommended Resources

Goals Module Overview

Learn more about the Goals Module and its key monitoring and reporting features.

Reg+Tech Magazine Volume 2 Issue 1

Learn about the changes of state consumer protection and the responsibility of financial services institutions to pursue operational excellence and a culture of compliance.

Reg+Tech Magazine Vol. 1 Issue 2

Regulatory and technology experts discuss innovation, CRA reforms, and how single-close construction loans are reenergizing rural America.

chevron-down linkedin facebook pinterest youtube rss twitter instagram facebook-blank rss-blank linkedin-blank pinterest youtube twitter instagram