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July 05, 2018

FDIC released a statement on implementation of the Economic Growth, Regulatory Relief, and Consumer Protection (EGRRCP) Act amendments to the Home Mortgage Disclosure Act (HMDA). The statement provides information on forthcoming guidance from CFPB on applicability of the Act to HMDA data collected in 2018, in addition to the information on formatting and submission of HMDA data. The agencies are retaining their diagnostic examination approach regarding the HMDA data collected in 2018 and reported in 2019.

This Financial Institution Letter applies to all FDIC-supervised institutions subject to HMDA and Regulation C. The HMDA exemption applies to institutions with assets at or below a threshold specified in Regulation C, that is, to Institutions with total assets under USD 1 billion. HMDA, which is implemented by Regulation C, requires certain financial institutions to collect, report, and disclose information about their mortgage lending activity. The EGRRCP Act, enacted on May 24, 2018, provides partial exemptions for some insured depository institutions from reporting certain HMDA data points. The partial exemptions are generally available to insured depository institutions and insured credit unions as follows:

  • For closed-end mortgage loans, if the institution originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years.
  • For open-end lines of credit, if the institution originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.

For institutions filing HMDA data collected in 2018, the Act will not affect the format of the Loan/Application Registers (LAR). An exemption code will be provided for data fields to which a partial exemption applies. In March 2018, FFIEC had also revised the guide to HMDA reporting, which provides a summary of key HMDA provisions, including information about the HMDA data collection, reporting, and disclosure requirements, along with the purpose of these requirements. Later this summer, CFPB expects to provide further guidance on the applicability of the Act to HMDA data collected in 2018.


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Keywords: Americas, US, Banking, Disclosures, HMDA, EGRRCP Act, Reporting, Regulation C, FDIC

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