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The Bureau of Consumer Financial Protection (previously the CFPB) issued a rule Friday to implement and clarify the requirements of the Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155) pertaining to the Home Mortgage Disclosure Act (HMDA). Updates to the filing instructions guide for HMDA data collected in 2018 were also released Friday.

S. 2155 adds a threshold for those institutions that are required to collect and report certain HMDA data points added by the Dodd-Frank Act. The bureau's rule clarifies that these institutions – including insured credit unions – have the option to "report exempt data fields as long as they report all data fields within any exempt data point for which they report data."

The rule also:

• clarifies that only HMDA reportable loans and lines of credit count toward the thresholds for these exemptions;
• clarifies which data points in Regulation C are covered by these exemptions; and
• appoints a "non-universal loan identifier for partially exempt transactions for institutions that choose not to report a universal loan identifier."

The bureau on Friday said it will likely release a future rulemaking to incorporate these interpretations and procedures into Regulation C in order to further implement S. 2155.

NAFCU has available a summary guide detailing credit union-related provisions of S. 2155, including those related to HMDA.