The CFPB has released an updated version of the HMDA Small Entity Compliance Guide. We’re not certain why it’s called a “small entity” guide, as any institution subject to HMDA would benefit from reviewing it. It also has nothing to do with small entities and is certainly not small being it’s 138 pages long!
The guide was updated to reflect the “small filer” exemptions granted earlier this year (loans between 25-499 in each of the last 2 years). There are also some clarifications to other parts of the regulation. For example, Section 4.1.2 clarifies which transactions count when determining if a loan-volume threshold has been met. Section 5.8. clarifies the loan amount to report when a counteroffer is made. There are other numerous technical corrections throughout the Guide, as well.
We encourage you to review the Guide to ensure you are on the right track! If you need more HMDA training, we’ve got the solutions! We’ve conducted several webinars in 2018 and have more planned for 2019 that can provide with you an in-depth training on the requirements of this complicated regulation. Check out our store for these great training opportunities!