2019 HMDA Asset-Size Exemption

The Consumer Financial Protection Bureau announced the adjusted asset-size exemption threshold for depository institutions for HMDA (Regulation C). The exemption threshold has been increased from $45 million to $46 million. Based on this adjustment, banks, savings associations, and credit unions with assets of $46 million or less as of December 31, 2018 are exempt from collecting data in 2019. Remember, 2018 HMDA data is reportable by March 1, 2019. If you need assistance with scrubbing your HMDA data for 2018, contact Regulation Solutions today!

Data Points Covered by Partial Exemptions

The Bureau of Consumer Financial Protection issued an interpretive and procedural rule on August 31, 2018, to implement and clarify section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act, which amended certain provisions of the Home Mortgage Disclosure Act (HMDA). The rule allows certain insured depository institutions and insured credit unions (based on thresholds for the number of closed-end and/or open-end loans originated during a given year) to be partially exempt for certain data point reporting.  Below is a chart detailing the data points covered by the partial exemptions and the correct code to use on the HMDA LAR to signify exemption.

Regulatory Solutions has developed proprietary software to complete your HMDA Scrubs. Please contact us today to discuss how we can help you ensure your HMDA data is correct

 

Data Points Covered by Partial Exemptions

Data Points Covered by Partial Exemptions Correct Code for Exemption
§ 1003.4(a)(1)(i) – Universal Loan IdentifierUnique, within the insured depository institution, loan or application identifier that can be up to 22 characters
§ 1003.4(a)(9)(i) – Property Address (street address, city, zip code)Exempt
§ 1003.4(a)(12) – Rate SpreadExempt
§ 1003.4(a)(15) – Credit Score1111
§ 1003.4(a)(15) – Name and Version of Credit Scoring Model1111
§ 1003.4(a)(16) – Reasons for Denial1111 (Leave the remaining Reason for denial data fields blank)
§ 1003.4(a)(17) – Total Loan Costs or Total Points and FeesExempt
§ 1003.4(a)(18) – Origination ChargesExempt
§ 1003.4(a)(19) – Discount PointsExempt
§ 1003.4(a)(20) – Lender CreditsExempt
§ 1003.4(a)(21) – Interest RateExempt
§ 1003.4(a)(22) – Prepayment Penalty TermExempt
§ 1003.4(a)(23) – Debt-to-Income RatioExempt
§ 1003.4(a)(24) – Combined-Loan-to-Value RatioExempt
§ 1003.4(a)(25) – Loan TermExempt
§ 1003.4(a)(26) – Introductory Rate PeriodExempt
§ 1003.4(a)(27) – Non-Amortizing Features
Balloon Payment
Interest-Only Payment
Negative Amortization
Other Non-Amortizing Features
1111 (enter code for each one)
§ 1003.4(a)(28) – Property ValueExempt
§ 1003.4(a)(29) – Manufactured Home Secured Property Type1111
§ 1003.4(a)(30) – Manufactured Home Land Property Interest1111
§ 1003.4(a)(32) – Multifamily Affordable UnitsExempt
§ 1003.4(a)(33) – Submission of Application1111
§ 1003.4(a)(33) – Initially Payable to Your Institution 1111
§ 1003.4(a)(34) – Mortgage Loan Originator IdentifierExempt
§ 1003.4(a)(35) – Automated Underwriting System (AUS)1111 (Leave the remaining AUS blank)
§ 1003.4(a)(35) – Automated Underwriting System Result1111 (Leave the remaining AUS results blank)
§ 1003.4(a)(36) – Reverse Mortgage Flag1111
§ 1003.4(a)(37) – Open-End Line of Credit Flag1111
§ 1003.4(a)(38) – Business or Commercial Purpose Flag1111

HMDA Compliance Alert: CFPB Proposes New Changes

On April 13, 2017, the Consumer Financial Protection Bureau issued a much-ask-for proposal to clarify and facilitate HMDA compliance with the 2015 updates to the Home Mortgage Disclosure Act rule set to take effect next year. According to the CFPB, “The proposed changes would help financial institutions comply with the 2015 HMDA Final Rule by clarifying the information they are required to collect and report about their mortgage lending.”

“These changes are monumental to HMDA collection and reporting requirements and will require a substantial amount of planning to implement the new data fields,” stated Rhonda Wannemuehler, Executive Vice President of Regulatory Solutions. “The CFPB gave the industry about three years to become compliant to the updates released in October 2015 with most of the requirements taking effect in January 2018.”

Read the full article on HousingWire.

Consumer Financial Protection Bureau website to review the proposal and other quick references. 

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