NCUA, the CFPB and other federal financial regulators have issued a joint statement describing amendments to the Home Mortgage Disclosure Act that are required by the Economic Growth, Regulatory Relief, and Consumer Protection Act, S.2155.
The agencies noted that S.2155 established partial HMDA reporting exemptions for some credit unions and banks.
In particular, the law provides partial exemptions from certain HMDA requirements that are generally available to federally insured financial institutions for closed-end mortgage loans if fewer than 500 closed-end mortgages in each of the two preceding calendar years were originated, and for open-end lines of credit if the credit union originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.
The changes do not affect NCUA’s supervision approach to compliance with requirements for recording and reporting 2018 HMDA data. The statement explains that for all credit unions filing HMDA data collected in 2018, the new law will not affect the format of the Loan/Application Registers. Rather, LARs will be formatted according to the previously released 2018 Filing Instructions Guide for HMDA Data Collected in 2018. If a credit union does not report information for a certain data field due to the partial exemptions, the credit union will enter an exemption code for the field specified in a revised 2018 Filing Instructions Guide that the Bureau expects to release later this summer.
Additionally, the agencies stated that the CFPB expects to provide further guidance later this summer on the applicability of the new law to HMDA data collected in 2018.
To view the joint statement, click here.