HMDA; HMDA; HMDA
Written by Steve Van Beek
A couple of HMDA items for your Wednesday.
HMDA Asset Threshold. Â Today, the CFPB published the HMDA asset threshold in the Federal Register. Â Institutions below $41 million in assets - as of December 31, 2011 - are exempt from HMDA reporting for 2012. Â The CFPB was quite a bit tardy on disclosing the HMDA asset threshold. Â 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. Â 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. Â The NCUA Report contains articles from various offices at NCUA - including the Office of Consumer Protection. Â The February article from the OCP discusses Fair Lending Examinations and how the NCUA uses HMDA data during the process. Â The article also mentions common areas of confusion that it sees as credit unions. Â Give this article a read as it might be an area of focus in the future. Â