CFPB Proposed Rule to Amend HMDA Regulation C

In Client and Friends Memos, HMDA by BMG Memorandum

In the May 13, 2019, Federal Register (84 FR 20972, click here) the Consumer Financial Protection Bureau (CFPB) published a proposed rule to amend Regulation C to: (i) propose two alternatives to increase the threshold for reporting data about closed-end mortgage loans so that institutions originating fewer than either 50 closed end mortgage loans, or alternatively 100 closed-end mortgage loans, …

HMDA Asset-Size Exemption Threshold Increased for 2019 – Regulation C, Supplement I, Paragraph 1003.2-2(g)

In Client and Friends Memos, HMDA by BMG Memorandum

In the January 31, 2019, issue of the Federal Register (Vol. 84, No. 513, click here) the Bureau of Consumer Financial Protection published a final rule amending the official staff commentary in Supplement I to Regulation C (12 CFR part 1003), which implements the Home Mortgage Disclosure Act, to reflect a change in the asset-size exemption threshold for banks, savings …

CFPB Releases Beta Version of 2018 HMDA Data Platform

In Client and Friends Memos, HMDA by BMG Memorandum

As a companion to the HMDA Examiner Transaction Testing Guidelines memorandum posted on our website yesterday, www.bmandg.com/resources/, this memorandum advises you that the CFPB has released a beta version of the 2018 HMDA data platform.   The beta release provides financial institutions an opportunity to become familiar with the 2018 HMDA Platform and determine whether their sample 2018 data comply …

HMDA Examiner Transaction Testing Guidelines

In Client and Friends Memos, HMDA by BMG Memorandum

As the 2018 HMDA data reporting deadline of March 1, 2019, is approaching, this memorandum is to remind our clients who report HMDA date of the Federal Financial Institutions Examination Council’s HMDA Examiner Transaction Testing Guidelines published last year on August 22, 2017, which will apply to the examination of HMDA data collected in 2018. The federal agencies that are …

CFPB Issues HMDA Interpretive Rule

In Client and Friends Memos, HMDA by BMG Memorandum

In the September 7, 2018, issue of the Federal Register (83 FR 45325, click here), the Consumer Financial Protection Bureau issued an interpretive and procedural rule (the “Interpretive Rule”) to implement and clarify the requirements of section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act signed into law on  May 24, 2018 (the “Act”), which amends section …

Asset-size Thresholds Revised for HMDA and TILA in 2018

In Client and Friends Memos, HMDA, TILA by BMG Memorandum

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

In Client and Friends Memos, HMDA by BMG Memorandum

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.

Regulation C (HMDA) Amendments

In Client and Friends Memos, HMDA by BMG Memorandum

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.

CFPB Proposed Amendments to HMDA Regulation C

In Client and Friends Memos, HMDA by BMG Memorandum

In the April 25, 2017, issue of the Federal Register (82 FR 19142, click here) the CFPB published a proposed rule, with a request for public comment, to make technical corrections to and to clarify certain requirements adopted by the Home Mortgage Disclosure (Regulation C) final rule (2015 HMDA Final Rule), which was published in the Federal Register on October 28, 2015 (80 FR 66128). The proposed rule also proposes a new reporting exclusion.