Separately, the Federal Financial Institutions Examination Council (FFIEC) members issued "FFIEC HMDA Examiner Transaction Testing Guidelines" (guidelines) for the FFIEC members' examination staff to use in assessing the accuracy of the HMDA data that financial institutions record and report. The guidelines include a data sampling process that involves prioritizing designated data fields for review or reviewing all data fields within a sample. The guidelines themselves, however, do not establish designated key data fields. In an effort to promote efficiency, coordination, and consistency, the OCC, the FRB, and the FDIC jointly identified and designated 37 of the HMDA data fields to be collected beginning January 1, 2018, pursuant to the HMDA amendments, as key fields for purposes of testing and validating bank data. In identifying the key fields, the OCC, the FRB, and the FDIC considered a variety of factors, including the HMDA's requirements, the goal of ensuring the efficiency of bank examinations, and the effective validation of HMDA data important to evaluating compliance with the Community Reinvestment Act and fair lending requirements. The OCC, the FRB, the FDIC also took into account the likelihood that a data field would be reported correctly based on past examination experience., OCC Bulletin 2019-12 informs national banks, federal savings associations, and federal branches and agencies about key data fields that the OCC has determined examiners will typically use to test and validate the accuracy and reliability of home mortgage loan data collected beginning in 2018., .