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.