In the October 29, 2019, issue of the Federal Register (84 FR 57946) the Bureau of Consumer Financial Protection (CFPB) issued a...
Read articles below for analysis and discussion of recent trends by BM&G’s industry experts.
CFPB Proposed Rule to Amend HMDA Regulation C
In the May 13, 2019, Federal Register (84 FR 20972, click here) the Consumer Financial Protection Bureau (CFPB) published a...
HMDA Asset-Size Exemption Threshold Increased for 2019 – Regulation C, Supplement I, Paragraph 1003.2-2(g)
In the January 31, 2019, issue of the Federal Register (Vol. 84, No. 513, click here) the Bureau of Consumer Financial...
CFPB Releases Beta Version of 2018 HMDA Data Platform
As a companion to the HMDA Examiner Transaction Testing Guidelines memorandum posted on our website yesterday,...
HMDA Examiner Transaction Testing Guidelines
As the 2018 HMDA data reporting deadline of March 1, 2019, is approaching, this memorandum is to remind our clients who report...
CFPB Issues HMDA Interpretive Rule
In the September 7, 2018, issue of the Federal Register (83 FR 45325, click here), the Consumer Financial Protection Bureau...
Asset-size Thresholds Revised for HMDA and TILA in 2018
In the December 27, 2017 issue of the Federal Register, the following annually revised asset-size thresholds were published to be effective January 1, 2018: Home Mortgage Disclosure Act/Regulation C (82 FR 61145) The CFPB has added comment -2 under the definition “Financial institution” in §1003.2(g) of the Staff Commentary to Regulation C (12 CFR part 1003) to increase the asset-size exemption threshold for banks, savings associations, and credit unions for HMDA data collected in 2018 to $45 million. Therefore, effective January 1, 2018, banks, savings associations, and credit unions with assets at or below $45 million as of December 31, 2017, are exempt from collecting HMDA data for 2018. (Note: An institution’s exemption from collecting HMDA data in 2018 does not affect its responsibility to report data it was required to collect in 2017.)
CFPB Issues Public Statement Regarding 2018 HMDA Data
On December 21, 2017, the CFPB issued a Public Statement for HMDA data collected in 2018 and reported in 2019. In the Public Statement, the CFPB states that it does not intend to require data resubmission unless data errors are material or assess penalties with respect to errors in data collected in 2018 and reported in 2019, and that any examinations of 2018 HMDA data will be diagnostic to help institutions identify compliance weaknesses and will credit good-faith compliance efforts.
CFPB Launches Beta Test Version of HMDA Platform
Today the CFPB announced the beta launch of the new HMDA Platform. For your information and use, the text of the CFPB announcement is reprinted below:
Regulation C (HMDA) Amendments
In the September 13, 2017, issue of the Federal Register (82 FR 43088, click here) the CFPB published a final rule amending its 2015 HMDA (Regulation C) Final Rule to: (i) make technical corrections and clarify certain requirements; (ii) temporarily increase the threshold for collecting and reporting data about open-end lines of credit for a period of two years so that financial institutions originating fewer than 500 open-end lines of credit in either of the preceding two years would not be required to begin collecting such data until January 1, 2020; and (iii) adopt a new reporting exclusion.