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OCC Bulletin 2017-31 | August 25, 2017

Home Mortgage Disclosure Act: Updated FFIEC Examiner Transaction Testing Guidelines


Chief Executive Officers and Compliance Officers of National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties


The Office of the Comptroller of the Currency (OCC) is issuing this bulletin to inform national banks, federal savings associations, and federal branches and agencies (collectively, banks) and all OCC examining personnel about new Federal Financial Institutions Examination Council (FFIEC) examination procedures for testing and validating the accuracy and reliability of home mortgage loan data that will be reported under the Home Mortgage Disclosure Act (HMDA) rule effective January 1, 2018.

Note for Community Banks

This bulletin applies to all banks subject to HMDA data collection and reporting requirements.


Transaction testing guidelines have been revised to reflect the new reporting requirements. Specifically, the procedures

  • establish transaction testing guidelines based on a statistical sampling methodology.
  • provide direction to examiners in determining error rates for expanded data fields, such as applicant race and ethnicity.
  • establish error rate thresholds for determining when an institution is expected to correct and resubmit reported data.
  • provide examples that demonstrate how procedures are applied in specific cases.

The FFIEC members anticipate incorporating the new transaction testing guidelines into updated FFIEC HMDA examination procedures that reflect the revised requirements of the amended HMDA rule. The full updated HMDA examination procedures are in development.

Further Information

Please contact Vonda Eanes, Director for CRA and Fair Lending Policy, Compliance Risk Policy Division, at (202) 649-5470.


Grovetta Gardineer
Senior Deputy Comptroller for Compliance and Community Affairs

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