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 304(i) of the Home Mortgage Disclosure Act (HMDA) by adding partial exemptions from HMDA’s requirements for certain insured depository institutions and insured credit unions1. These HMDA requirements are in section 304(b)(5) and (6) added by the Dodd-Frank Act that requires reporting of new data points2 and also gives the CFPB discretionary authority to add other data points. In the 2015 HMDA Final Rule3, the CFPB implemented these new data points required by HMDA section 304(b)(5) and (6) and added a number of additional data points.


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