HMDA and CRA Data Collection and Submission 2025: Keep Getting it Right

Over the past week, each day has added to growing uncertainty in the regulatory environment. This stems from a recent email by Russell Vought, the newly appointed director of the Office of Management and Budget, instructing the CFPB to halt work on proposed rules, postpone the effective dates of finalized rules not yet in effect, and suspend both ongoing and new investigations. The email also ordered the bureau to “cease all supervision and examination activity.”

Since its inception in 2011 under the Dodd-Frank Act in response to the 2008 financial crisis, the CFPB has been instrumental in helping prevent widespread abuses in the financial sector such as predatory lending; unfair, deceptive acts or practices; and lack of transparency.

While enforcement activities in these areas have been temporarily (at least) suspended, data collection and submission requirements for both HMDA and CRA have not changed. Submission timeliness and accuracy are just as important now as they ever were, with the filing deadline of March 1 (officially March 3 with March 1 being a non-business day).

Accordingly, it’s important to remember that the prudential regulators, state regulators, and consumer advocacy organizations will continue to utilize this data. CRA and Fair Lending Examinations conducted by the Federal Reserve Bank, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation will proceed according to schedule. The reliability and accuracy of the collected and reported data form the foundation of these reviews.

Inaccurate data will inevitably result in rescrubbing and resubmission, potentially leading to costly penalties and reputational damage, not to mention getting an exam off on the wrong foot. Additionally, HMDA and CRA data collected today is subject to lookback periods that may extend across changes in leadership in Washington, D.C.

Change is and always has been constant in the regulatory environment. What goes up will most certainly come down. Enforcement actions ease, enforcement actions tighten. It is incumbent upon compliance staff to remain steady in both calm and choppy waters to ensure their institutions keep getting it right for the communities they serve.

About Marquis

At Marquis, we endeavor daily to help our clients keep getting it right on behalf of their customers and the communities they serve. Our Compliance Data Platform has evolved through more than 30 years of regulatory change, never missing a beat in helping our clients hit the ever-moving target of lending compliance. Our solution’s full suite of HMDA, CRA, Fair Lending, and Redlining reporting, along with built-in mapping, eases the burden of getting and staying on the right track with regulatory expectations. Our industry experts and top-of-the-line support staff are here to help guide our clients as they navigate this tumultuous landscape.

Contact us today to discover more about how our solutions keep data accurate, usable, and exam ready.