How to Approach 2025 HMDA and CRA Data Collection Amidst CFPB Changes

February 12, 2025
CFPB Changes Since its establishment in 2011 under the Dodd-Frank Act, the Consumer Financial Protection Bureau (CFPB) has played a pivotal role in financial services regulation, including the collection and compilation of mandated data. This responsibility notably includes Home Mortgage Disclosure Act (HMDA), originally enacted in 1975, with data collection authority shifting to the CFPB […]

CFPB Changes

Since its establishment in 2011 under the Dodd-Frank Act, the Consumer Financial Protection Bureau (CFPB) has played a pivotal role in financial services regulation, including the collection and compilation of mandated data. This responsibility notably includes Home Mortgage Disclosure Act (HMDA), originally enacted in 1975, with data collection authority shifting to the CFPB from the Federal Financial Institutions Examination Council (FFIEC) in 2011. As the current administration sets its priorities and agenda for the Bureau, recent days have seen both CFPB changes implemented and additional changes proposed. The pressing question now is the durability of these changes, and precisely when a definitive vision for the Bureau’s future will emerge. Amidst this transitional period, submission season is in full swing. The data collection requirements for HMDA along with the Community Reinvestment Act (CRA), although supervised by prudential regulators, remain firmly in place. And with the deadline for data submission on March 1st (March 3rd in 2025), getting it right remains just as critical as ever.

Current enforcement may be temporarily paused, but make no mistake, the impact of this data stretches far and wide. The timeline for this year’s public-facing HMDA peer data release remains unchanged, as it is also mandated by law. Once released, prudential regulators, state regulators, and consumer advocacy groups will closely examine it, using the data to shape their own assessments of financial institutions. Meanwhile, CRA exams are proceeding as scheduled, with prudential regulators relying heavily on CRA and HMDA data, backed by rigorous data integrity reviews to confirm data accuracy and reliability. Now is not the time for financial institutions to relax in their compliance posture. While the CFPB may be in transition, state regulators have already launched their own enforcement initiatives; some of which may be just as stringent as federal laws.

With CFPB changes, regulatory uncertainty and shifting enforcement priorities, one thing remains constant: the significance of fair lending and compliance. The scrutiny of HMDA and CRA data by regulators and advocacy groups underscores the continued expectations for financial institutions, regardless of the CFPB’s evolving direction. Now more than ever, compliance professionals must stay vigilant, not just to meet deadlines, but to uphold the core principles of fair and responsible lending.

In the world of fair lending and compliance, we don’t rely on any single agency to keep us accountable. Our commitment goes beyond simply “getting it right” - we do it because we’re driven by the belief that every qualified person deserves the opportunity to own a home, start a business, or access credit to build a better future. Compliance isn’t about checking a box; it’s about ensuring fairness, equity, and financial inclusion for all. While the CFPB may be in transition today – evident by the occasional “404: Page not found” message on their homepage – the agency’s core resources remain fully operational. Financial institutions still have access to vital tools, guidance, and regulatory information for complying with HMDA, Regulation B, and other fair lending requirements. The expectations haven’t changed, and neither should our dedication to doing what’s right.

We understand that meeting these expectations may be challenging, especially when support is harder to come by. If HMDA Help Desk responses are delayed due to short-staffing at the Bureau, rest assured RiskExec is here, fully equipped to help you get the job done. We’ve always taken pride in easing the stress that comes with submission, and this year is no different. Our software continues to evolve to align with regulatory requirements and client needs, and we’re offering extended submission support hours, just as we always do, to help you navigate the process with confidence. At RiskExec, we understand compliance doesn’t pause just because enforcement is temporarily delayed. The expectations remain, the data still matters, and the stakes are just as high. While others may hesitate amid regulatory uncertainty, we remain steadfast—delivering the tools, insights, and expertise you need to stay ahead.

Compliance is not a matter of choice; it is a commitment to accuracy, integrity, and regulatory excellence. In today’s evolving landscape, ensuring precise and timely HMDA and CRA submission requires the right technology and expertise. Now is not the time to take a wait-and-see approach; now is the time to take control. Whether you need to validate your HMDA and CRA data accuracy, prepare for an upcoming examination(s), or stay proactive in an ever-changing regulatory environment, RiskExec is here to support you. Our cutting-edge solutions help you streamline processes, reduce costs, modernize your compliance strategy, and navigate regulatory complexities with confidence.

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