The Federal Financial Institutions Examination Council (FFIEC) issued HMDA Examiner Transaction Testing Guidelines (the Guidelines) establishing procedures for examination staff to use when validating HMDA data, but those guidelines did not establish designated key data fields. Various agencies have now addressed this issue.
The Guidelines include a data sampling process that involves prioritizing designated data fields for review, or reviewing all data fields within a sample.
We have provided guidance in previous posts to assist in bank-internal reviews of HMDA data integrity.
However, the Guidelines themselves do not establish designated key data fields. The FRB, the FDIC, and the OCC have since jointly identified and Designated Key HMDA Data Fields, consistent with their traditional practice of designating key fields considered to be most important to ensuring the integrity of analyses of HMDA data.
FDIC compliance examination staff will prioritize the Designated Key HMDA Data Fields in reviewing data that is collected by financial institutions in or after 2018 pursuant to the HMDA Amendments.
The document with details and the list of fields can be accessed below: