- The annual Federal Financial Institutions Examination Council (“FFIEC”) HMDA data plays an important part in assisting mortgage lenders prevent, detect, and correct potential issues through advanced analytics and peer benchmarking. As a result, the FFIEC HMDA data is an important element in a mortgage lender’s “responsible” governance, risk management, and compliance “conduct.”
- The annual Federal Financial Institutions Examination Council (“FFIEC”) HMDA data file is finalized approximately two months before it is released to the public.
- Delaying the release of this data to the public compromises the efficiency and effectiveness of responsible conduct protocols.
The following chart summarizes the “Hold Days” (i.e., the number of days between the date the data file was last modified and the date the file was released to the public) for the three most recent annual FFIEC HMDA data files:
Source: FFIEC website.
The delay, averaging 71 days, is likely due in part to providing the FFIEC time to prepare the analysis included in the Press Release issued in connection with the release of the HMDA data. Delaying the release of the HMDA data places mortgage lenders at unnecessary risk by delaying its use in their preventative, detective and corrective governance, risk management, and compliance controls.Source: FFIEC website.
Releasing the HMDA data earlier does not prevent the FFIEC from issuing their analysis at a subsequent date.
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“It is a capital mistake to theorize before one has data. Insensibly one begins to twist facts to suit theories, instead of theories to suit facts.” ― The Adventures of Sherlock Holmes, A Scandal in Bohemia
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