Happy 4th of July. We’ve got more “independence” for you to celebrate – independence from the Expanded HMDA Data requirements that is! On July 5th, the CFPB announced how “Small Filers” will report their 2018 HMDA data. This is relief provided by the Economic Growth and Regulatory Relief Act (S.2155).
If your institution originated less than:
- 500 closed-end mortgage loans in each of the two preceding calendar years, or
- 500 open-end lines of credit in each of the two preceding calendar years, and
- Your institution has at least a satisfactory CRA rating, then
You are a “Small Filer” and exempt from the expanded HMDA data requirements for the applicable loans or lines.
This is not a complete list!
Small Filers will still be subject to HMDA and all filers will use the same Loan Application Register (LAR) format and platform (with a test version available later this year). However, the CFPB will provide an exemption code for use by “Small Filers” for those exempt data fields. This exemption code is anticipated to be released later this summer, along with a revised 2018 Filing Instructions Guide.
The CFPB also said further guidance will be coming. As guidance rolls out, we’ll keep you updated. We’ll also be conducting a webinar and live training with complete details on this information after it is released. We’ve got your back. Stay tuned!