HMDA Compliance Chart
In our August Newsletter, we covered what we know regarding the HMDA data reporting requirements for those banks considered to be “small filers”. This small filer exemption was originally announced by the CFPB on July 5th.
You are considered a “small filer” (and exempt from full HMDA data reporting in 2018) IF your bank originated less than:
- 500 closed-end mortgage loans in each of the two preceding calendar years (2016 & 2017); or,
- 500 open-end lines of credit in each of the two preceding calendar years (2016 & 2017); and,
- Your institution has at least a satisfactory CRA rating.
While this seems pretty straightforward, it’s actually a little more complicated than that. Since our mission is to put things in Plain English, we created an HMDA Volume Test Chart to help walk you through the requirements.
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!