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September 07, 2018

CFPB issued an interpretive and procedural rule to implement and clarify the requirements of section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCP Act), which amended certain provisions of the Home Mortgage Disclosure Act. This interpretive and procedural rule became effective on September 07, 2018.

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

Effective Date: September 07, 2018

 

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

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