BCFP Issues Rule Clarifying HMDA Amendments
On August 31, 2018, the Bureau of Consumer Financial Protection (BCFP) issued an interpretive and procedural rule implementing section 104(a) of the Economic Growth, Regulatory Relief and Consumer Protection Act (Act) which amended the Home Mortgage Disclosure Act (HMDA). The BCFP also issued an update to the Filing Instructions Guide (FIG) for 2018 HMDA data.
The Act decreases the regulatory burden of HMDA on smaller banks and credit unions. The interpretive and procedural rule provides clarification on how the Act is to be applied. Specifically, the rule clarifies that banks and credit unions covered by the partial exemption have the option of reporting exempt data fields as long as they report all data fields within any exempt data point for which they report data. The rule also clarifies that only loans and lines of credit that are otherwise HMDA reportable count toward the thresholds for the partial exemption and which of the HMDA data points are covered by the partial exemptions. Finally, the rule assigns a non-universal loan identifier for partially exempt transactions for institutions that choose not to report a universal loan identifier.
CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.
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