California DFPI plans to adopt the Mortgage Compliance Dataset for mortgage origination exams
On October 29, the California DFPI announced in a CSBS blog post that it plans to implement the Mortgage Compliance Dataset (MCD) in residential mortgage origination compliance examinations. The MCD, developed by the Mortgage Industry Standards Maintenance Organization (MISMO) with state regulators and industry, is one of the first CSBS Catalyst initiatives, a series of exploratory projects focused on using technology to address state financial regulatory and supervisory challenges. The MCD is a standardized loan data file that replaces the Loan Examination File state regulators previously used in origination exams. It covers first- and second-lien closed-end mortgages and includes data fields for compliance testing under federal lending laws, with state-level requirements to be added in future versions. The DFPI said the MCD and associated processes support a risk-based approach to file selection that directs examiners to areas of potential compliance issues instead of relying on random samples.
The DFPI stated that it intends to fully adopt the MCD in origination exams “as soon as possible.” According to the post, the State Examination System (SES) September 2026 release was to publish a new standard Information Request requiring licensees to provide electronic closed-loan data in the MCD format in exams where the examining state elects to use it. The DFPI plans to use the Information Request to assess the readiness of originators and loan origination system vendors for full implementation in 2027, and it will participate in a multistate effort to assess industry-wide readiness. By the end of the first quarter of 2027, the DFPI will schedule a pilot examination through SES using the MCD Information Request, MCD-based data, and compliance technology vendors to test the standard and related processes.