Top Consumer Violations in 2024 for State Member Banks
Collection and Reporting Requirements of the Home Mortgage Disclosure Act (HMDA)
The 2025 issue of Consumer Compliance Outlook is now available on the Federal Reserve System’s Consumer Compliance Outlook webpage. Included in this release are the top Consumer Violations in 2024 for State Member Banks and for the third year in a row, HMDA has dominated the top spot. These are the two most frequently cited violations in 2022, 2023, and 2024.
It’s remarkable that such an overwhelming majority of violations cited by the Federal Reserve in the past three years involved inaccurate collection and reporting of residential mortgage data. Because fair lending examinations rely, in part, on HMDA data, examiners validate this data. Thus, it is important for financial institutions to ensure their compliance management systems can meet existing and future requirements.
It could be a red flag if your current process doesn’t find errors and suggests a review of your HMDA CMS and data validation process might be prudent.
The latest Consumer Compliance Outlook and data on the top 2024 violations cited can be accessed here - https://www.consumercomplianceoutlook.org/
Please contact SCA if you would like to discuss a review of your HMDA CMS and/or your current HMDA data integrity validation process. Please contact our Director, Bill Dolan, at WDolan@scapartnering.com or by phone at (617) 694-2617 and schedule a time to speak with us today.
