CFPB Issues Rule to Clarify Provisions of Home Mortgage Disclosure Act

To support implementation of the rule, CFPB updated the Filing Instructions Guide for HMDA data collected in 2018, along with the Regulatory and Reporting Overview Reference Chart. The rule provides clarification and guidance on five general items:

• Partially exempt institutions have the option to report data points covered by the partial exemption. If a data point covered by the partial exemption includes multiple data fields, partially exempt institutions report all of the data fields if they choose to report at least one of the data fields.
• The terms “closed-end mortgage loan” and “open-end line of credit” include only loans and lines of credit that are otherwise reportable under HMDA.
• Partially exempt institutions are not required to report 26 data points (in Regulation C) that are specified in this rule.
• Partially exempt institutions are required to report a non-universal loan identifier if they choose not to report a universal loan identifier.
• For a given reporting year, the Community Reinvestment Act (CRA) ratings used to determine whether the CRA reporting exception applies are the two most recent CRA ratings as of December 31 of the preceding calendar year.

Related Links

• Rule in Federal Register
• Consumer Financial Protection Update (PDF)
• Filing Instructions Guide for HMDA
• Regulatory and Reporting Overview Reference Chart (PDF)

Effective Date: September 07, 2018

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