HMDA Asset Threshold for 2010
By David Dickinson
The FRB has announced the 2010 HMDA asset threshold. Really, they announced it isn't changing.
For 2009, the threshold was $39 million. During the twelve-month period ending in
November 2009, the CPIW decreased by 0.98 percent. That decrease results in a new threshold,
before rounding, of about $38.62 million dollars, which must be rounded to the nearest million
dollars pursuant to Regulation C. As a result, the exemption threshold remains $39 million.
Thus, depository institutions with assets of $39 million or less as of December 31, 2009 are
exempt from collecting data in 2010. An institution's exemption from collecting data in 2010
does not affect its responsibility to report data it was required to collect in 2009.
With all of the regulatory changes, it's good to know that some things don't change. If you didn't know, there are two ways to get around HMDA reporting:
- Sell assets to get to the $39 million threshold; or,
- Sell the banking offices is MSAs.
You think I'm kidding. 