Compliance Blog

Feb 15, 2012
Categories: Home-Secured Lending

HMDA; HMDA; HMDA

Written by Steve Van Beek

A couple of HMDA items for your Wednesday.

HMDA Asset Threshold.  Today, the CFPB published the HMDA asset threshold in the Federal Register.  Institutions below $41 million in assets - as of December 31, 2011 - are exempt from HMDA reporting for 2012.  The CFPB was quite a bit tardy on disclosing the HMDA asset threshold.  As I blogged about in early January, the Federal Reserve (who had authority for Regulation C prior to Dodd-Frank) had historically notified institutions in December of the reporting threshold for the upcoming year.

The uncertainty that institutions hovering near the asset threshold have felt over the past 6 weeks of 2012 - where they were in regulatory limbo - won't show up in any calculations of "regulatory burden" - but it was real.  That is for sure.

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CRA-HMDA Reporter.  One of the interesting aspects of HMDA is that Regulation C passed to the CFPB but the actual HMDA reporting and submission process has stayed with the Federal Reserve (at least for now).  The Fed has a new CRA-HMDA Reporter that was just released.  This report is published every two years and contains very detailed information on the technical aspects of HMDA reporting - such as recreates, census tract changes and changes from Dodd-Frank.

Be sure to pass this newsletter on to the folks at your credit union who work with HMDA.

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NCUA's Office of Consumer Protection.  The NCUA Report contains articles from various offices at NCUA - including the Office of Consumer Protection.  The February article from the OCP discusses Fair Lending Examinations and how the NCUA uses HMDA data during the process.  The article also mentions common areas of confusion that it sees as credit unions.  Give this article a read as it might be an area of focus in the future. Â