Whether reforms enacted in May reducing Home Mortgage Disclosure Act reporting fields for small lenders mean they still have to collect the data, has been a point of confusion for many financial institutions.

Deputy Director for the FDIC's division of depositor and consumer protection, Jonathan Miller, says, "From our point of view, we do not think the law requires you to collect the data if you don't have to report it."

Financial institutions have been eagerly waiting for more HDMA guidance since May. Banks and credit unions are wondering whether or not they still need to collect the HMDA data (in order to protect themselves), even if they don't have to report it.

While many have been curious about what kind of effect this will have on financial processes, Ballard Spahr attorney Richard Andreano says, "I don't think this has a large effect on CRA or fair-lending because… it doesn't stop the agencies on a case-by-case basis from getting whatever fair-lending data they can get."

More formal guidance from the CFPB is expected this summer.

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