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CUNA, BCFP Present HMDA Partial Exemption Info, Resources
Friday, October 19, 2018 6:55 AM

Credit Union National Association hosted a webinar on Oct. 10 with Bureau of Consumer Financial Protection staff on changes to Home Mortgage Disclosure Act (HMDA) reporting requirements. A recording of the webinar is available now, free to CUNA members.

Partial exemptions from HMDA reporting are part of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155), and the bureau issued an interpretive final rule in August clarifying the exemptions.

Among other things, the rule clarifies that only loans and lines of credit that are otherwise HMDA reportable count toward the threshold for the partial exemptions and also clarifies which of the data points in Regulation C are covered by partial exemption.

Generally, an insured financial institution does not need to collect or report certain data with respect to:

  • Closed-end mortgage loans if the institution originated fewer than 500 such loans in each of the two preceding calendar years; and
  • Open-end lines of credit if it originated fewer than 500 such lines of credit in each of the two preceding calendar years.

According to bureau staff, its operational approach remains unchanged. Each year, it will provide an updated Filing Instruction Guide to assist with the filing process; users will then compile one Loan Application Register and submit the file through the HMDA platform.

The bureau will offer flexibility for 2018 submissions, however, allowing users to take partial exemptions for any of the eligible data points if they are below the threshold requirements. These partial exemptions can be taken at any point in the year and are retroactive to dates on or after Jan. 1, 2018.