The Consumer Financial Protection Bureau (CFPB) issued a public statement last week announcing “that the bureau does not intend to require data resubmission unless data errors are material or assess penalties with respect to errors for data collected in 2018 and reported in 2019 under the Home Mortgage Disclosure Act (HMDA).”

The Bureau’s statement went on to say it intends to reconsider various aspects of the bureau’s 2015 HMDA rule, such as the institutional and transactional coverage tests and the rule’s discretionary data points. Beginning on Jan. 1, 2018, financial institutions will submit HMDA data collected in 2017 and beyond using the bureau’s new online platform.

Gregg Oberg, of Braintree-based Spillane Consulting Assoc., clarified what this means for lenders in his weekly newsletter this morning. Oberg said the CFPB seems to understand that the new HMDA collection rules are complex and require complicated new software to gather, collate and report. Oberg said the CFPB is going to try to help diagnose lenders’ non-material data reporting problems rather than issue punitive fines for minor issues.

“As of now, nothing has substantively changed about the HMDA Rule itself,” Oberg wrote. “All of your preparation still applies, and there is no reason to toss the policy and procedure out the window.”

Oberg advised lenders to continue to prepare to fully comply with the new HMDA rules starting in 2018.

“While the future of the rule is questionable at this early stage, I think its clear that HMDA in 2018 has gotten less risky,” Oberg wrote. “Reading the limited language we have available, there will be a lot of effort and thought towards defining ‘good faith efforts’ and whether an error is ‘material’ for data re-submission purposes.”