Agencies Issue Statement on Implementing S. 2155’s HMDA Reporting Exemptions

The Consumer Financial Protection Bureau, FDIC and OCC today each issued statements acknowledging the partial exemptions granted under S. 2155 — the new regulatory reform law — for certain Home Mortgage Disclosure Act data reporting requirements for some insured depository institutions and credit unions. The law provides a partial exemption to banks and credit unions for closed-end mortgage loans if the institution originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years, and for open-end lines of credit if the institution originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.

The agencies noted that the new law will not affect the format of the loan/application registers for institutions filing HMDA data collected in 2018. Institutions that no longer have to report information for certain data fields as a result of the partial exemption will enter an exemption code for the specified field. More information will be provided in a revised filing instructions guide, which the CFPB expects to issue later this summer.

The agencies also reminded institutions that — as previously announced — they will not require data resubmission for HMDA data collected in 2018 and reported in 2019 unless data errors are material. They added that they do not intend to assess penalties for errors in 2018 HMDA data, and will credit good-faith compliance efforts in their diagnostic examinations of 2018 HMDA data.


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