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.
- News Release
- Statement (PDF)
- CFPB HMDA Reporting Information
- FFIEC Guide to HMDA Reporting, March 2018 (PDF)
Keywords: Americas, US, Banking, Disclosures, HMDA, EGRRCP Act, Reporting, Regulation C, FDIC
Previous ArticleBCBS Publishes Responses to Consultation on Market Risk Standards
PRA, via the consultation paper CP12/20, proposed changes to its rules, supervisory statements, and statements of policy to implement certain elements of the Capital Requirements Directive (CRD5).
EIOPA published the financial stability report that provides detailed quantitative and qualitative assessment of the key risks identified for the insurance and occupational pensions sectors in the European Economic Area.
EBA published its risk dashboard for the first quarter of 2020 together with the results of the risk assessment questionnaire.
EBA announced that the next stress testing exercise is expected to be launched at the end of January 2021 and its results are to be published at the end of July 2021.
PRA published the consultation paper CP11/20 that sets out its expectations and guidance related to auditors’ work on the matching adjustment under Solvency II.
MAS published a statement guidance on dividend distribution by banks.
APRA updated its capital management guidance for banks, particularly easing restrictions around paying dividends as institutions continue to manage the disruption caused by COVID-19 pandemic.
FSB published a report that reviews the progress on data collection for macro-prudential analysis and the availability and use of macro-prudential tools in Germany.
EBA issued a statement reminding financial institutions that the transition period between EU and UK will expire on December 31, 2020; this will end the possibility for the UK-based financial institutions to offer financial services to EU customers on a cross-border basis via passporting.
SRB published guidance on operational continuity in resolution and financial market infrastructure (FMI) contingency plans.