CFPB Revises Asset-Exemption Threshold for HMDA Data Collection in 2013
by: Margaret Wright, Esq.
The Consumer Financial Protection Bureau (CFPB) has issued a Final Rule which revises the Home Mortgage Disclosure Act (HMDA) regarding adjustment of the asset exemption threshold definition for HMDA data collection by depository institutions.
Banks, saving associations and credit unions with assets that are less than or equal to $42 million as of December 31, 2012 are now exempt from collecting HMDA reportable data in 2013. This Final Rule is effective December 31, 2012 and does not impact exemption for previously non-exempt institutions from 2012 HMDA data reporting requirements.
HMDA requires the CFPB to adjust the asset exemption threshold annually based on the change in the Consumer Price Index for Urban Wage Earners and Clerical Workers. The exemption threshold definition can be found in the HMDA Staff Commentary Financial Institutions section, now also reflecting the new title of “banks, savings associations and credit unions” where previously these institutions were described as “depository institutions”.
HMDA has also been recently brought back into the spotlight by the CFPB through fair lending guidelines, where HMDA data review is often the starting point in an examination. Dodd-Frank also outlines the requirement for additional HMDA data collection fields, to ultimately be implemented by the CFPB.
View the complete Asset-Exemption Threshold Final Rule on AllRegs:
http://www.allregs.com/ao/main.aspx?did2=b7750c30a09745c386261a106e9eb528
About the Author:
Margaret is Vice President & Senior Counsel at Bankers Advisory and serves as the firm’s Director of Regulatory Compliance Research. She is a graduate of Stonehill College and received her Juris Doctor from Suffolk University Law School. She is admitted to the Massachusetts Bar and serves on the Compliance Committee for the Massachusetts Mortgage Bankers Association. She can be reached at margaret@bankersadvisory.com
Margaret Wright, JD, is regulatory compliance director with CLA. She is a graduate of Stonehill College and earned her juris doctor at Suffolk University Law School. She is admitted to the Massachusetts Bar.
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