Changes to Home Mortgage Disclosure Act (HMDA) requirements under last year’s Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA, S. 2155) are reflected in two updated webinars and one new webinar published recently by the Consumer Financial Protection Bureau (CFPB).
The first two webinars referred to above – “HMDA Webinar 1,” published in 2016 to provide an overview of a final rule; and “HMDA Webinar 2,” published in 2017 on identifiers and data points related to applicants and borrowers – were updated Aug. 29, the bureau noted. The bureau also on Aug. 29 posted a new webinar, “HMDA Webinar 3,” which provides an overview of data points not covered in the first two.
Under EGRRCPA changes to HMDA, insured depository institutions that originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years, or fewer than 500 open-end lines of credit in each of the two preceding calendar years, are exempt from some data collection and reporting under HMDA (implemented by the bureau through Regulation C).
The bureau, in a small-entity compliance guide published last year, notes that the partial exemptions are unavailable to an insured depository institution if it received a rating of “needs to improve record of meeting community credit needs” during each of its two most recent Community Reinvestment Act (CRA) examinations or a rating of “substantial noncompliance in meeting community credit needs” on its most recent CRA examination.
RR: Bureau publishes small-entity HMDA guide, reflects relief law changes (Oct. 30, 2018)